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CFPB Updates TRID Compliance Guide, Guide to Forms

Mon, Oct 17, 2016

District Of Columbia

The Consumer Financial Protection Bureau Thursday released updated versions of its Truth in Lending Act-Real Estate Settlement Procedures Act integrated disclosures (TRID) rule Small Entity Compliance Guide and Guide to Forms. The two documents are part of TRID resources the bureau has available to assist with understanding, implementing and complying with TRID.

The Guide to Forms document has been updated to incorporate guidance from existing webinars and guidance, and includes additional clarifications on various aspects of both the Loan Estimate and Closing Disclosure form. It also includes several miscellaneous administrative changes.

The Guide to Forms was last updated in July 2015.

Changes to the Small Entity Compliance Guide include updates on:

  • Record retention requirements for the Closing Disclosure;
  • Completing and formatting the Loan Estimate and Closing Disclosure;
  • Delivery requirements for the Loan Estimate and the special information booklet;
  • Requirements upon receiving an application;
  • Disclosing and determining good faith for services the borrower may shop;
  • Disclosing seller-paid costs and providing seller disclosures;
  • Providing revised Loan Estimates and corrected Closing Disclosures;
  • Guidance on construction loans;
  • The absence of a HUD-1 comparison chart in the Closing Disclosure.

The update also includes additional guidance on providing revised Loan Estimates anytime before the Closing Disclosure and revisions to standardize the terminology for “revised Loan Estimates” and “corrected Closing Disclosures.”