On Friday, July 29, 2016, the Consumer Financial Protection Bureau (CFPB) proposed revisions to the Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) Integrated Disclosure Rule (the “TRID Rule”), as promised. This formal TRID clarification process is welcome news for many who in their good-faith efforts to fully comply with the TRID Rule have been struggling to ascertain the meaning of various requirements, including those that could expose originators and their assignees to material liability. If crafted appropriately, the revisions could eliminate much of this uncertainty and reduce enforcement and private civil litigation risk once they become effective.
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