Bureau publishes 11 new FAQs (and answers) about TRID compliance

Eleven frequently asked questions (and answers) about integrated disclosures related to real estate lending — including about providing loan estimates to consumers — are now posted on its website, the federal consumer financial protection agency said Thursday.

The FAQs published by the Consumer Financial Protection Bureau (CFPB) are aimed at assisting compliance with the Truth in Lending Act (TILA)/Real Estate Settlements Procedures Act (RESPA) Integrated Disclosure Rule (also known by a third acronym: TRID), the bureau said.

Four topics are covered in the series of 11 questions: corrected closing disclosures and the three business-day waiting period before consummation; model forms; construction loans; and providing loan estimates to consumers.

For providing loan estimates to consumers, the FAQ answer states that, generally, a creditor is responsible for ensuring that the loan estimate is delivered to a consumer or placed in the mail to the consumer no later than the third business day after receipt of the consumer’s “application” for a mortgage loan subject to the TRID rule. Under that rule, an “application” consists of the submission of the consumer’s name, income, social security number (to obtain a credit report), property address, estimate of the property’s value, and the mortgage loan amount sought.

“If the consumer submits these six pieces of information, the requirement to provide a Loan Estimate is triggered, and the creditor must ensure that the Loan Estimate is delivered or placed in the mail within three business days,” the FAQ states. “The creditor or, if a mortgage broker receives a consumer’s application, either the creditor or the mortgage broker may mail or deliver the Loan Estimate.”

TILA-RESPA Integrated Disclosure FAQs

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