The CFPB staff presented an informational webinar on Tuesday, April 12, 2016, to address several issues with the TILA/RESPA Integrated Disclosure (TRID) rule. The webinar, titled Know Before You Owe Mortgage Disclosure Rule: Post-Effective Date Questions & Guidance, focused on responding to specific industry raised questions. Specific topics of discussion included:
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Determining what fees must be disclosed;
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APR changes that require a new 3-day waiting period;
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Lender and seller credits as they relate to the APR and finance charge;
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The calculation of the Total Interest Percentage (TIP);
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Disclosure of the owner’s title insurance policy premium when disclosures produce a negative premium amount;
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Flood insurance premium disclosures;
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Disclosure of escrow account balances credited from an existing loan;
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Separate borrower and seller Closing Disclosures;
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Disclosure of whether a loan is assumable;
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How to address upfront fees collected from the consumer for items that cost less than the collected amount; and
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Disclosure of a principal curtailment.
As we have previously written for the last TRID rule webinar, the fact that the entire presentation appeared to be scripted word-for-word was interesting considering the fact that the CFPB has refused industry requests to issue informal guidance in writing.
