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ARTICLE · 12 FEBRUARY 2019

CFPB Issues FAQs For The TRID Rule

Morrison Foerster
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The Consumer Financial Protection Bureau (CFPB) has posted a new compliance tool on its website - answers to frequently asked questions (FAQs) about the TILA-RESPA Integrated Disclosure Rule ("TRID Rule").

United StatesFinance and Banking
Richard Fischer
Richard Fischer
Kathleen C. Ryan
Kathleen C. Ryan
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The Consumer Financial Protection Bureau (CFPB) has posted a new compliance tool on its website - answers to frequently asked questions (FAQs) about the TILA-RESPA Integrated Disclosure Rule ("TRID Rule"). Apparently in response to industry requests for more guidance, the FAQs clarify a creditor's obligation to provide a new three-day waiting period along with a corrected Closing Disclosure (CD) when a term previously disclosed has changed; how creditors may use model forms that do not reflect the CFPB's 2017 amendments to the Rule; and the impact of a recent TILA amendment to the requirement for corrected disclosures. The FAQs were posted without advance notice or comment, signaling that perhaps the CFPB will dispense with lengthy processes when providing written guidance. What follows is a brief summary of the FAQs.

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Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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