Have you submitted your feedback on the proposed changes that the Consumer Financial Protection Bureau released this summer? The comment period is quickly drawing to a close.
With the countdown to the October 18, 2016, deadline well under way, it’s a good time to recap why the comment period is so important, what’s already changed, and what lenders need to know going forward.
TRID Challenges and Comments
The TILA-RESPA Integrated Disclosures rule went into effect on October 3, 2015. Soon after, mortgage and real estate industry professionals began compiling their grievances. Regulations regarding the sharing of closing disclosure forms probably received the most ire.
To their credit, the Consumer Financial Protection Bureau listened to the pleas of professionals across the nation and opened the discussion for proposed rule changes. By July of 2016, a 300-page proposal containing the phrase “seeks comment” more than 150 times was released. Thus began the comment period allowing anyone to review the rule changes and submit suggestions on where the CFPB went too far or not far enough.
Lenders and real estate firms reacted positively to the CFPB’s efforts to clarify confusing language, make selective amendments, and open the forum for discussion. Many saw a couple of key changes as clear victories for the affected industries.
In a Housing Wire article, a cross section of mortgage professionals mostly agreed that the CFPB took a big step in the right direction. They were impressed by the Bureau’s willingness to address issues in the original wording of the rule and their enthusiasm for courting public feedback to fuel future changes.
Changes in Progress
Notably, in their 300-word proposal released in July, the CFPB sided with the National Association regarding closing disclosure (CD) forms. NAR argued that sharing between lender and real estate agent was common practice before TRID and nothing had happened to justify the new restrictions that went into effect on October 3, 2015.
The CD issue appears to be on its way to resolution, but widespread participation in the comment period is one way to ensure that happens.
What Lenders Need to Know
Lenders interested in offering their perspective on dealing with TRID over the past year, or on the recently proposed changes, the comment period only lasts until October 18, 2016.
If you would like to know more about the latest TILA-RESPA Integrated Disclosures proposal or how you can submit your feedback to the CFPB, you should visit the Federal Register website.