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There may be some light at the end of the TRID tunnel, and it’s not HMDA coming this way (just yet). In a letter sent to industry trade associations CFPB Director Richard Cordray finally officially acknowledged the challenges posed by TRID compliance.
He also announced that as a result of such challenges CFPB is in the process of drafting a Notice of Proposed Ruling Making intended to address some of the industry’s concerns (The Letter). There may be a crack in the wall.
Since the implementation of the new rules, many questions have been raised by lenders, closing agents and their attorneys, and the secondary markets. These include such things as how and when to disclose certain information, treatment of title insurance premiums and the disclosure of Construction to Permanent Loans.
CFPB has attempted to address many of the industry’s concerns and questions through initially written commentary with subsequent training guides and webinars, supplemented by some unofficial commentary and a few letters. Nice stuff, but nothing really concrete that the stakeholders can take to the bank that provides any real comfort level for full compliance. There is still too much uncertainty and confusion; too many stumbling blocks.
So maybe this is just the opening the industry needs; a doorway through the CFPB’s wall of silence on these issues. A way to finally sit down and present issues and information that can be used to formulate reasonable solutions with much clearer guidance for full TRID compliance.
It’s time to turn those stumbling blocks into stepping stones. It’s time to get involved. CFPB will be conducting meetings in late May and early June with stakeholders to discuss issues and the process for the proposed rulemaking. If you have legitimate concerns, questions and/or suggestions you need to get involved. Get these to your association, or the CFPB immediately. Speak up; now’s your chance. Bust through the wall.
The stakes are high. Under the new rules, a lender may incur a $5,000 – up to $1 million civil monetary penalty for TRID violations. We can’t allow walls to stand in our way!
