WASHINGTON—The CFPB has released additional guidance – via a factsheet and additional FAQs – for its Truth in Lending Act (TILA)/Real Estate Settlement Procedures Act (RESPA) integrated disclosure (TRID) rule.
Of note, the factsheet provides clarity on what to do when the TRID formula for disclosing title insurance yields a negative number, NAFCU explained.
In the factsheet section on negative owner's title insurance, the Bureau recommends double-checking calculations but acknowledges that there are some instances where the TRID calculation methodology could be correct in disclosing a negative number. It provides an example of rate prices that would yield a negative number.
The factsheet also addresses:
- Disclosure on loan estimate and closing disclosure, specifically explaining lender's title insurance and owner's title insurance
- Disclosure of simultaneous title insurance on the loan estimate and closing disclosure
- Differences between state disclosures and TRID disclosure requirements for simultaneous rates
- Simultaneous issuance if a seller agrees to pay the amount of the full owner's title insurance premium
The TRID FAQs have been updated to include lender credits on the total of payments disclosure, the optional signature line, and separating consumer and seller information.