Fall 2017 Federal Highlights

CFPB Issues Final Rule Revising TRID

The Consumer Financial Protection Bureau (CFPB) issued its final rule revising certain provisions of TRID. The rule was effective October 10, 2017. However, compliance with the final rule is not required on the effective date. Rather, mandatory compliance is required for applications received on or after October 1, 2018 (except for the provisions relating to the escrow closing notice and partial payment disclosure requirements.) The rule also provides for an optional compliance period. Beginning October 10, 2017, a person may comply with the final rule but is not required to do so.

The final rule implements the CFPB’s informal guidance regarding construction loans. The rule also clarifies the applicable tolerance when a settlement provider list is not given. Further, the rule implements a tolerance for the total of payments calculation. The final rule does not make any changes to address the “black hole.” Rather, the CFPB has asked for additional comments on this issue.

CFPB Issues Regulation Z Annual Threshold Adjustments

The Consumer Financial Protection Bureau (“CFPB”) issued a final rule amending the high-cost mortgage thresholds and the qualified mortgage thresholds in Regulation Z. The amendments are effective January 1, 2018.

The CFPB also issued final rules amending Regulation B and the mortgage servicing requirements in Regulations X and Z. Regulation B was amended to facilitate the collection of government monitoring information in compliance with the new HMDA requirements.

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