The CFPB recently issued final amendments to the TILA/RESPA Integrated Disclosure (TRID) rule and a proposal to further amend the TRID rule. The CFPB has also issued an Executive Summary of the amendments.
Although the amendments will become effective 60 days after publication in the Federal Register, mandatory compliance with the amendments will be required for applications received on or after October 1, 2018. The CFPB advises that during the optional compliance period between the effective date and October 1, 2018, a party may comply with the amendments “all at one time or phase in the changes over time (even within the course of a transaction).”
The CFPB also addresses uncertainty regarding what loans are subject to the existing partial payment disclosure requirement for mortgage transfer notices and the existing escrow closing notice requirement. The requirements were included in the same final rule that contains the original TRID rule provisions, even though they are not integrated disclosure requirements. This led to uncertainty as to whether the requirements apply to all transactions within the scope of the requirements, or only those transactions for which the application was received on or after October 3, 2015, which is the effective date of the original TRID rule. The CFPB clarifies that compliance with the requirements becomes mandatory on October 1, 2018, regardless of when the application was received.