“Know Before You Owe” Is Still a Work in Progress: CFPB Proposes TRID Changes and Clarifications
18 August 2016
Mayer Brown Legal Update
The Consumer Financial Protection Bureau (“CFPB”) issued a Notice of Proposed Rulemaking (“NPRM”) on July 29, 2016, proposing a number of amendments to its TILA-RESPA Integrated Disclosure rule (“TRID”). Since the CFPB indicated in April 2016 that it would engage in formal rulemaking to provide “greater certainty and clarity” to the mortgage industry under TRID, the industry has been anxiously awaiting the proposal to see which of the many issues the CFPB would address. While it may not have touched upon every issue the mortgage lending industry has raised, the NPRM indicates that the CFPB understands some of the challenges market participants have faced. This Legal Update highlights and summarizes the significant proposals in the 293-page NPRM, for which public comments must be submitted by October 18, 2016.