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Special Alert: Proposed Amendments to the TRID Rule and Introducing Buckley Sandler's TRID Resource Center

Buckley Sandler Special Alert

Clinton R. Rockwell, Jeremiah S. Buckley, Joseph M. Kolar, John P. Kromer, Brandy A. Hood, Benjamin K. Olson, Jeffrey P. Naimon

Buckley Sandler is pleased to announce our new TILA-RESPA Integrated Disclosure (“TRID”) Resource Center. The TRID Resource Center is a one-stop shop for TRID issues, providing access to Buckley Sandler’s analysis of the TRID rule and the CFPB’s amendments, transcripts of CFPB webinars providing guidance on the rule, and other CFPB publications that will facilitate implementation of the rule. In particular, the TRID Resource Center will address the following recent developments:

  • Proposed amendments. On October 10, 2014, the CFPB proposed amendments to theTRID rule that, if adopted, would: (1) allow creditors to provide a revised Loan Estimate on the business day after the date the interest rate is locked, instead of the current requirement to provide the revised Loan Estimate on the date the rate is locked; and (2) correct an oversight by creating room on the Loan Estimate form for the disclosure that must be provided on the initial Loan Estimate as a condition of issuing a revised estimate for construction loans where the creditor reasonably expects settlement to occur more than 60 days after the initial estimate is provided. The proposal would also make a number of additional amendments, clarifications, and corrections, including:
    • Add the Loan Estimate and Closing Disclosure to the list of loan documents that must disclose the name and NMLSR ID number of the loan originator organization and individual loan originator under 12 C.F.R. § 1026.36(g);
    • Provide additional guidance related to the disclosure of escrow accounts, such as when an escrow account is established but escrow payments are not required with a particular periodic payment or range of payments; and
    • Clarify that, consistent with the requirement for the Loan Estimate, the addresses for all properties securing the loan must be provided on the Closing Disclosure, although an addendum may be used for this purpose.

    Comments on the proposal are due by November 10, 2014. For your convenience,we have updated our summary of the TRID rule to identify the most significant proposed changes.

  • Unofficial Transcript of the CFPB’s October 1 Webinar on the Loan Estimate Form. As it has with past webinars where CFPB staff provide informal guidance,Buckley Sandler has prepared a transcript of the CFPB’s October 1, 2014 webinar (hosted by the Federal Reserve) addressing frequently asked questions regarding the Loan Estimate form. The transcript is provided for informational purposes only and does not constitute legal opinions, interpretations, or advice by Buckley Sandler. The transcript was prepared from the audio recording arranged by the Federal Reserve and may have minor inaccuracies due to sound quality. In addition, the transcript has not been reviewed by the CFPB or the Federal Reserve for accuracy or completeness.

Other items in the TRID Resource Center include:

Questions regarding the matters discussed in this Alert may be directed to any of our lawyers listed below, or to any other Buckley Sandler attorney with whom you have consulted in the past.

 

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