CFPB Issues Statement on TRID Enforcement Concerns

The Consumer Financial Protection Bureau (CFPB) issued a statement on Wednesday, June 3, 2015, stating that its enforcement of the TILA-RESPA INTEGRATED DISCLOSURES (“TRID”) will be sensitive to mortgage lenders making a good faith effort to enforce the new rule. Richard Cordray, Director of the CFPB, addressed the statement to Senators Joe Donnelly and Tim Scott, and recognized that the implementation of TRID will post challenges to industry professionals. Cordray also outlined the CFPB’s plan for implementing the new rule.

Cordray was also adamant that TRID would not delay most closings, and clarified the three circumstances under which an additional 3-day review period, or re-disclosure, will be required:

1. An APR increase of more than 1/8 of a percent for fixed-rate loans, or 1/4 of a percent for adjustable loans. A decrease in APR will not require re-disclosure, if it is based on changes to interest rate or other fees.
2. The addition of a prepayment penalty
3. The loan product itself changes, (i.e., from fixed-rate to adjustable-rate)

Cordray closed his statement by saying that the CFPB’s support of the implementation of TRID will not end on August 1, and that regulators will be sensitive to lenders making good-faith efforts to enforce the new rule. To read the full statement, click here.

While this is a step in the right direction, both Congress and the mortgage industry quickly responded that still more was needed.

“Nearly 300 Senators and House Members have written to Director Cordray asking for a formalized hold harmless,” said U.S. Reps. Blaine Luetkemeyer (R-MO) and Randy Neugebauer (R-TX) in a joint statement. “Anything short of that is unacceptable.”

For more information on how NFM Lending is preparing for TRID, visit www.nfmlending.com/ready-for-TRID.

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