The Consumer Financial Protection Bureau (CFPB), recently issued a Request for Information (RFI) related to fees charged by providers of mortgages and related settlement services. In his statement, Director Chopra discussed...more
Late last week, the Consumer Financial Protection Bureau (CFPB) released an interpretive rule that provided much-welcome guidance related to the effect of the new Juneteenth National Independence Day on disclosure waiting...more
As previously reported, the bill signed into law by President Biden on June 17, 2021 to create the Juneteenth National Independence Day actually results in an important change under the Truth in Lending Act (TILA) and...more
On October 1, 2020, the Consumer Financial Protection Bureau (CFPB) released its rule assessment for a final Rule relating to mortgage disclosures. Known as the TRID Rule, the Bureau’s final Rule implemented requirements...more
On June 9, 2020, the CFPB published four new TRID FAQ’s and a TRID Factsheet (“Factsheet”). While the Factsheet is focused solely on the handling of title insurance disclosures under the rule, the FAQ’s cover various topics,...more
TRID Rescission Waiver Rule & ECOA Valuations FAQ - On April 29, 2020, the Consumer Financial Protection Bureau (CFPB) released additional information which Director Kathleen Kraninger said she hopes “will help consumers...more
The CFPB recently published 10 new TRID FAQs related to lender credits. Previously the CFPB staff provided informal verbal guidance regarding lender credits, and the 2017 amendments to the TRID rule, often referred to as...more
The CFPB recently published ten new TRID FAQs related to lender credits. Previously the CFPB staff provided informal verbal guidance regarding lender credits, and the 2017 amendments to the TRID rule, often referred to as...more
The CFPB recently updated the TRID rule FAQs to address questions about providing a Loan Estimate to consumers. The FAQs mostly confirm guidance previously provided by the CFPB in various forms. ...more
On July 11, 2019, I presented at the American Bankers Association webinar, entitled, “Mortgage Disclosure Cures and Corrections — Mitigating Liability.” Below is a summary of the points presented in the webinar and additional...more
On May 1, 2019, the Consumer Financial Protection Bureau (CFPB) released a Fact Sheet on the application of the TILA-RESPA Integrated Disclosure Rule (TRID) to assumptions of residential mortgage loans. The Fact Sheet appears...more
For years, the mortgage industry has urged the CFPB to issue informal written guidance on the TILA/RESPA Integrated Disclosure (TRID) Rule, as well as other rules. ...more
The CFPB recently issued revised TILA/RESPA Integrated Disclosure (TRID) rule guides to reflect the adoption of an amendment to the rule to fix the so-called “black hole” issue. ...more
In astronomy, there can be no escape from a black hole. In the world of residential mortgage lending, the CFPB has charted a new course, finally creating an escape from one of TILA/RESPA’s most impracticable rules. On April...more
The Consumer Financial Protection Bureau comes through with a solution to a particularly vexing disclosure rule. Our Financial Services & Products Group shines some light on the new TRID Rule that solves several problems but...more
Amendment Addresses the “Black Hole” Issue - On April 26, 2018, the Consumer Financial Protection Bureau (CFPB or Bureau) finalized an amendment to its TILA-RESPA Integrated Disclosure (TRID) Rule that addresses when...more
On February 14, 2018, the United States House of Representatives passed the TRID Improvement Act of 2017, H.R. 3978, by a vote of 245 to 171. The bill would amend the manner in which title insurance premiums are disclosed...more
The financial services industry — and the consumer financial services marketplace in particular — is experiencing significant innovation. Technology has facilitated the emergence of fintech as a major industry — fundamentally...more
The CFPB recently released a revised version of the TILA-RESPA Integrated Disclosure Rule Small Entity Compliance Guide. The revised version incorporates the recent amendments to the rule that became effective on October...more
In July, the CFPB finalized amendments to the TILA/RESPA Integrated Disclosure (TRID) rule. Published in the Federal Register earlier this month, the amendments will become effective on October 10, 2017, with a mandatory...more
As we reported previously, on July 7, 2017 the Consumer Financial Protection Bureau (CFPB) posted on its website long awaited amendments to the TILA/RESPA Integrated Disclosure (TRID) rule, and a proposal to address the...more
As we reported previously, the Consumer Financial Protection Bureau (CFPB) recently issued long-awaited amendments to the Truth in Lending Act (TILA)/Real Estate Settlement Procedures Act (RESPA) Integrated Disclosure (TRID)...more
Our Financial Services & Products Group gets to know the Consumer Financial Protection Bureau’s long-awaited final TILA and RESPA Integrated Disclosure (TRID) Rule. - The black hole - Highlighted variations - Possible...more
The Consumer Financial Protection Bureau (CFPB) released final amendments to its “Know Before You Owe” mortgage disclosure rule, which is also known as the TILA-RESPA Integrated Disclosure rule (TRID), on July 7, 2017. As...more
On July 7, the Consumer Financial Protection Bureau (Bureau) finalized amendments to federal mortgage disclosure requirements under the Real Estate Settlement Procedures Act (RESPA) and the Truth in Lending Act (TILA) that...more