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The Clock Starts Now: TRID Public Comments Begin

FHLBanks Poised for Meltdown; GSEs NotThe proposed updates to the CFPB’s TILA-RESPA Integrated Disclosure (TRID) rule [1], also known as the Know Before You Owe mortgage rule, were published in the Federal Register on Monday [2], thus launching the 64-day comment period for public comments on the proposal.

The comment period on the CFPB’s proposal runs through October 18, 2016. According to the CFPB, interested parties can submit comments identified by identified by Docket No. CFPB-2016-0038 or RIN 3170-AA61 [3], any of the following ways:

The TRID rule went into effect on October 3, 2015, and has been a source of much consternation within the industry among lenders and originators due to elevated risk environment it presents—namely, the cost of updating systems to be fully compliant.

In late April, CFPB Director Richard Cordray wrote a letter to financial industry trades and their members [6] recognizing the “operational challenges” the industry is experiencing as a result TRID implementation and said that the Bureau was considering making some “adjustments” in the regulation text to provide greater certainty and clarity.

The Bureau announced the proposed adjustments [1] in late July 2016; among the proposed changes were tolerances for the total of payments, a clarification that recording fees and transfer taxes may be charged in those transactions without losing eligibility for the exemption in order to promote housing assistance lending, expanding TRID’s coverage to include all cooperative units, and additional commentary to clarify how a lender may provide separate disclosure forms to the consumer and the seller.

The CFPB noted that when it published its 2012 proposal to integrate the TILA and RESPA disclosures, which was built from extensive early outreach and research, the Bureau received more than 2,800 comments.

Click here to view the CFPB’s proposal [2] as published in the Federal Register.