TRID Consierations in a COVID World

To help make things easier on both mortgage lenders and borrowers during this time of crisis, the Consumer Financial Protection Bureau (CFPB) is loosening some of its regulations under the TILA-RESPA Integrated Disclosures (TRID) rule.

The goal of the new “interpretive rule,” the bureau explains, is to make it “easier for consumers with urgent financial needs to obtain access to mortgage credit more quickly in the middle of the COVID-19 pandemic.”

“The bureau concludes in this interpretive rule that if a consumer determines that his or her need to obtain funds due to the COVID-19 pandemic 1) necessitates consummating the credit transaction before the end of the TRID Rule waiting periods or 2) must be met before the end of the Regulation Z Rescission Rules waiting period, then the consumer has a bona fide personal financial emergency that would permit the consumer to utilize the modification and waiver provisions, subject to the applicable procedures set forth in the TRID Rule and Regulation Z Rescission Rules,” the interpretive rule states.

“The bureau also concludes in this interpretive rule that the COVID-19 pandemic is a ‘changed circumstance’ for purposes of certain TRID rule provisions, allowing creditors to use revised estimates reflecting changes in settlement charges for purposes of determining good faith. This interpretive rule will help expedite consumers’ access to credit under the TRID rule and Regulation Z Rescission Rules.”

“The steps we are taking today will help consumers facing financial emergencies obtain access to mortgage credit faster,” says Kathleen L. Kraninger, director of the CFPB, in a statement. “The pandemic is resulting in consumers facing various challenges, and our temporary and targeted solutions are intended to ensure that consumers receive the credit they need in a timely manner.”

The CFPB says rule change will “also reduce regulatory uncertainty and allow creditors to focus their resources on meeting consumers’ needs.”


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