Amy Moser, VP mortgage services for $6.7 billion Mountain America CU, West Jordan, Utah
Amy Moser, VP mortgage services for $6.7 billion Mountain America CU, West Jordan, Utah, noted a variety of sources in the mortgage industry have suggested dozens of clarifications and changes to TRID over the last two years. She said there were a variety of amendments and clarifications that the CFPB addressed in the amendment, some that were adopted as submitted, some that were modified and adopted, and some that were rejected.
Among the rules the CFPB addressed were: a clarification that a Loan Estimate must be issued after the interest rate is initially locked if the Closing Disclosure has not yet been issued, even if all of the terms and conditions remain the same; clarification that co-ops are covered under the Know Before You Owe rule, regardless of whether states consider them real property or not; a requirement to provide post-closing escrow cancellation and partial payment disclosures; how tolerance cures and principal curtailments should be disclosed; and additional information on construction loans and simultaneous subordinate lien transactions.
“This is in no way a comprehensive list of what the Bureau addressed in its recent TRID ‘fix’ but a sampling of the 560-page document released [in July],” Moser said. “Among these was an appeal to address the ‘black hole’ that prevents creditors from using the Closing Disclosure to reset tolerances except in a very limited number of circumstances. Instead of finalizing any of the proposed amendments, the CFPB instead issued a concurrent proposal to address the issue later.”