Regulator puts focus for credit unions on TRID FAQs issued by consumer bureau – including ‘safe harbor’

Four “frequently asked questions” issued by the federal consumer financial protection agency last month about the TILA-RESPA Integrated Disclosure (TRID) rule are a focus of an National Credit Union Administration (NCUA) Consumer Financial Protection update released Thursday.

In particular, the update notes that the fourth of the FAQs (issued by the Consumer Financial Protection Bureau, CFPB) addresses whether use of a model form provides a safe harbor if the form does not reflect a TRID rule change finalized in 2017. “Appendix H to Regulation Z (TILA, the Truth in Lending Act) includes blank and non-blank model forms. If a credit union accurately completes the applicable model form, it meets the safe harbor,” NCUA states.

The brief update also notes that one FAQ covers a TRID rule change created by last year’s regulatory relief legislation (the Economic Growth, Regulatory Relief, and Consumer Protection Act, EGRRCPA, S. 2155). It also notes that three questions pertain to “closing disclosures” and the waiting period before mortgage loan consummation.

“Certain changes require a credit union to ensure members receive a corrected Closing Disclosure at least three business days before consummation,” the NCUA update notes. “Other changes require credit unions to provide a corrected Closing Disclosure at or before consummation.

CFPB Releases FAQs for Complying with TRID Rule Change