August 11, 2016
Clients and Friends,
The CFPB issued its long-awaited proposed rule to amend TRID on July 29, 2016. The proposal was intended to “formalize guidance in the rule, and provide greater clarity and certainty.” The press release is available at: http://www.consumerfinance.gov/about-us/newsroom/consumer-financial-protection-bureau-proposes-updates-know-you-owe-mortgage-disclosure-rule
The proposal is available on the CFPB’s website at: http://www.consumerfinance.gov/policy-compliance/rulemaking/rules-under-development/amendments-federal-mortgage-disclosure-requirements-under-truth-lending-act-regulation-z/
As a general matter, this proposal addresses many of the difficult compliance issues in the rule. It does not, however, address major policy issues such as the disclosure of title insurance, cures, or liability. But it is apparent that the CFPB put a great deal of work into this proposal, and thoughtfully considered much of the input from the public regarding compliance with the rule. The CFPB also explained the proposed changes and its reasoning for the changes in the preamble in a clear and concise manner, which is very helpful. As with any proposed rule, there are issues that the public may want to comment on to provide further input, especially considering the detailed nature of the proposed changes. But the CFPB’s effort and the quality of its proposal should be commended.
Please click here to download my summary of the proposal along with some of my thoughts on a few of the issues in the proposal. I organized the summary by subject area. I hope this summary provides a helpful starting point for your review of the proposal. Please let me know if I can be of any assistance in understanding the proposal or preparing a comment letter for your organization.