2020 CFPB TRID Developments

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The year 2020 marked the five-year anniversary of the TILA-RESPA Integrated Disclosure rule (TRID Rule). While the year passed without any additional formal rulemaking from the Consumer Financial Protection Bureau (Bureau or CFPB), the Bureau did issue clarifying guidance in several important areas throughout the year. Some of the guidance was specific to the time (i.e., in the midst of the COVID-19 pandemic), while other guidance addressed issues of longstanding concern under the Rule.

I. COVID-19 TRID GUIDANCE -

On May 4, 2020, the CFPB published in the Federal Register an interpretive rule that addressed two TRID-related issues arising from the COVID19 pandemic. The first issue dealt with the Rule’s pre-consummation timing requirements; the second issue addressed the Rule’s definition of “changed circumstances.”

Originally published in CCFL's Consumer Finance Law Quarterly Report, Vol. 75, Nos. 1 & 2, 2021.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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