The Consumer Financial Protection Bureau (CFPB) has announced that is requesting public comment on an assessment it will conduct on the TRID Integrated Disclosure Rule (the Truth in Lending Act and Real Estate Settlement Procedures Act).
The CFPB notes that part of the goal of the assessment is to address the TRID Rule’s effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act, the specific goals of the rule, and other relevant factors. The public is invited to comment on the feasibility and effectiveness of the assessment plan, recommendations to improve the assessment plan, and recommendations for modifying, expanding, or eliminating the TRID Rule, among other questions. The TRID Rule implemented the Dodd-Frank Act’s directive to combine certain mortgage disclosures that consumers receive under TILA and RESPA and requires that all creditors use standardized forms for most transactions. Creditors are also required to provide loan estimates and closing disclosures within three business days.
Earlier this year, as part of the CFPB’s Spring 2019 rulemaking agenda, the CFPB will be reviewing existing regulations, such as, "conducting an assessment pursuant to section 1022(d) of the Dodd-Frank Act of its regulations to consolidate various mortgage origination disclosures under the Truth in Lending Act and Real Estate Settlement Procedures Act."
The CFPB finalized part of this Notice of Proposed Rulemaking when it extended for two years the current temporary threshold for collecting and reporting data about open-end lines of credit under the Home Mortgage Disclosure Act (HMDA). The rule also clarifies partial exemptions from certain HMDA requirements which Congress added in the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA).
Comments may be submitted through the Federal eRulemaking Portal, by email at 2019-RFI-TRID@cfpb.gov, or by mail at at Comment Intake – TRID Assessment, Consumer Financial Protection Bureau, 1700 G Street, NW, Washington, DC 20552. The comment period will open once the notice is published in the Federal Register and the deadline for submissions is January 21, 2020.