WASHINGTON—The CFPB has released a new set of FAQs under the TILA-RESPA Integrated Disclosure (TRID) rule, specifically related to lender credits.
Largely under TRID, lender credits are subject to 0% tolerance so the disclosed number generally could not be modified, absent a change in circumstances. Trying to offer a "no closing cost" loan could put a lender at risk of having to refund borrowers cash if their estimate of lender credits ended up being higher than anticipated, NAFCU said.
There are 10 answers to lender credits FAQs that address tolerance limitation, "no closing cost" loan specifics, closing cost disclosures, and more. The Bureau began releasing FAQs on the TRID rule last year; other questions addressed relate to:
- Corrected closing disclosures and the three business-day waiting period before consummation
- Model forms
- Construction loans
- Providing loan estimates to consumers