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On July 7, 2017, nearly a year after issuing a Notice of Proposed Rulemaking (“NPRM”), the Consumer Financial Protection Bureau (“CFPB”) announced regulations to finalize changes and clarifications to the TILA-RESPA Integrated Disclosure rule (“TRID”). For the most part, the CFPB finalizes its proposals with modifications here and there to address issues and questions raised by public comments. The CFPB also declines to finalize certain proposals based on concerns for unintended consequences or borrower confusion. And, in one instance, the CFPB declines to finalize its proposal to address the “black hole” on resetting fee tolerances and instead offers a new proposal with a 60-day comment period. This Legal Update summarizes and highlights certain of the significant final regulations and how they differ from the CFPB’s NPRM.
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