WASHINGTON—The CFPB has finalized its updates to its Truth in Lending Act/Real Estate Settlement Procedures Act integrated mortgage disclosure rule.
The updates include adjustments on the sharing of disclosures with sellers and third parties, among other things.
The final rule is effective 60 days after its publication in the Federal Register and has a mandatory compliance date of Oct. 1, 2018. NAFCU told the Bureau last year that the rulemaking's initial proposed implementation period (120 days) did not offer enough time for credit unions to update systems with post-consummation disclosures.
"As the only financial services trade to oppose any CFPB authority over credit unions, NAFCU has long pressed the Bureau to improve the TRID rule and related guidance," said NAFCU Vice President of Regulatory Compliance Brandy Bruyere. "NAFCU will continue to push for more clarity and transparency wherever possible in the CFPB's approach to TRID compliance."
The CFPB's final rule, also referred to as the TRID "fix," addresses tolerance provisions for the total of payments, incorporates informal guidance into the rule and extends the rule’s coverage to include all cooperative units rather than just transactions secured by real property, among other things, NAFCU explained.
Accompanying the final rule, the CFPB also issued a proposal addressing when a creditor can use a closing disclosure instead of a loan estimate when determining if the estimated closing cost was disclosed in good faith, noted NAFCU. The proposal will be out for a 60-day comment period once published in the Federal Register.