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Past Event
5 October 2016



"Know Before You Owe" Is Still a Work in Progress: CFPB Proposes TRID Changes and Clarifications

With only a few days left to meet its July 2016 target release date, the Consumer Financial Protection Bureau issued a Notice of Proposed Rulemaking on July 29, 2016, offering a number of amendments to its TILA-RESPA Integrated Disclosure rule (“TRID”). While the CFPB’s 293-page proposal does not touch on every issue that industry participants have raised, it appears to be a step in the right direction, indicating that the CFPB is sensitive to some of the challenges market participants face. Yet the CFPB’s proposal leaves unaddressed significant issues that will continue to impact compliance with TRID requirements and ongoing discussions about liability and lenders’ ability to sell closed mortgage loans.

Join Phil Schulman, Holly Spencer Bunting and Charles Weinstein for a 60-minute webinar highlighting certain of the TRID changes and clarifications proposed by the CFPB. This webinar will cover:

  • How the CFPB is addressing the “black hole” for resetting tolerances
  • Proposed clarification regarding the sharing of borrower and seller Closing Disclosures with parties to the transaction
  • Updated proposed guidance on completion of the disclosures for construction-to-permanent mortgage loans
  • Proposed changes to tolerances applicable to closing costs where a written list of settlement service providers is required
  • A summary of proposed changes to certain disclosures on the CFPB’s Loan Estimate and Closing Disclosure forms, including changes to the Cash to Close table and the disclosure of rounded numbers and percentages
  • Whether the CFPB addresses cures for disclosure errors and resulting lender liability
  • Whether the CFPB is proposing to change the disclosure of title insurance premiums for simultaneously issued policies
  • A summary of other significant clarifications to address ambiguities and resulting challenges under TRID
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