It’s been almost a year since we got a TRID proposal with the belief that a final rule would come rather quickly! Well, the quickly part didn’t exactly happen, but we do now have a Final Rule! The CFPB has also released an Executive Summary.
The Rule formally implements CFPB guidance on a number of things, including:
- Simultaneous Seconds;
- Construction loans;
- Calculating Cash to Close;
- Escrow account disclosures;
- Expiration dates for Loan Estimate closing costs;
- The “In 5 Years” and TIP calculations;
- Seller credits;
- Service Provider Lists;
- Disclosing property taxes and property value; and,
- Sharing Disclosures with other parties.
The Rule also implements a tolerance for the total of payments like we have with the finance charge.
This rule is effective 60 days after publication in the Federal Register, with compliance mandatory October 1, 2018.
What the Rule doesn’t address is when a Closing Disclosure can be used in place of a Loan Estimate to determine tolerances. A separate proposal has been issued on that with comments due 60 days after it’s published in the Federal Register.
We are in the process of digesting this Rule further and will keep you up to speed in our Newsletter. Stay tuned!
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!