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Compliance: Final rule analysis of TRID changes available

Mon, Aug 14, 2017

CUNA’s final rule analysis of the Consumer Financial Protection Bureau’s (CFPB) changes to the Truth in Lending Act-Real Estate Settlement Procedures Act integrated disclosures (TRID) rule is now available. The bureau published the final rule in the Federal Register last week, making it effective October 10, with a mandatory compliance date of Oct.ober 1, 2018.

TRID took effect Oct. 3, 2015, combining separate mortgage disclosures required under the Truth in Lending Act and Real Estate Settlement Procedures Act.

  • Expansion of the partial exemption for certain down payment and homeowner assistance programs;
  • Clarification on the treatment of cooperatives;
  • Clarifications on construction loans;
  • Treatment of escrow accounts (cancellations and disclosures); and
  • Information sharing clarifications.

The rule applies to all credit unions that originate covered transactions under TRID.

For purposes of TRID, a covered transaction is defined as any closed-end consumer credit transaction secured by real property, except:

  • A home equity line of credit;
  • A mortgage secured by an interest in a timeshare plan;
  • A reverse mortgage;
  • A temporary or bridge loan with a term of 12 months or less;
  • A construction loan with a term of 12 months or less; and
  • A mortgage secured by a mobile home or dwelling that is not attached to real property.