Is it a grace period or not? That is the big question surrounding the very recent CFPB letter on post TRID implementation enforcement actions. Although CFPB has announced it will be sensitive to lenders that make a “good faith” effort to comply with the new rules, they do not go as far as to say there will be no enforcement…
A Bill was been introduced in Congress, supported by a recent letter from the American Bankers Association (Letter), to allow a “hold harmless’’ period from enforcement actions after the new TILA RESPA Integrated Disclosure (TRID) rules take effect. Creditors, which have yet to satisfactorily test their system’s readiness to ensure compliance with the new rules, fear severe reprisals from the…
With the TRID changes looming large, Brokers are taking their concerns about fee disclosures to Congress. It seems Brokers have realized that, the fees they disclose at application must be accepted by any Lender with which they decide to subsequently register a loan. The Brokers believe the new rules governing the Loan Estimate will make it more difficult for them…
A bi-partisan bill was introduced in Congress last week that intends to provide all lenders with a temporary reprieve from enforcement actions for violations under the new TILA-RESPA Integrated Disclosure (TRID) rules (Relief). Under the proposal, lenders would not be subject to enforcement actions through year end 2015. Eligibility would be based on the lender’s “good faith” efforts to comply…
Shockingly, a recent survey, done by Capsilon Corp, a company providing cloud-based document sharing, imaging and collaboration for business, reveals that a large number of mortgage lenders may not be fully prepared to implement the required TRID changes (Survey). Time is running out for these lenders.To date, the CFPB has made it clear that they do not intend to grant…
Just a reminder, as if you need it, the new TRID rules become effective with loan apps taken as of August 1, 2015. Besides the two new disclosures that everyone is preparing for, there is another big change. With an application, you need to provide the consumer with a new settlement cost booklet (New Booklet). Like the HUD-1, the current…
