The Consumer Financial Protection Bureau’s (CFPB) announcement that it was planning a Notice of Proposed Rulemaking (NPRM) in July to make needed adjustments to the TILA RESPA Integrated Disclosures Rule was well received by industry organizations that have been calling for clarification.
“We appreciate Director Cordray’s consideration of our concerns regarding the need for greater clarity on the TRID rules,” said National Association of Federal Credit Unions (NAFCU) Director of Regulatory Compliance Brandy Bruyere. “This is a welcome first step and there is still a lot of work to be done in order to truly address the ambiguities in the TRID rule. We look forward to the bureau’s continuing efforts to facilitate the compliance process.”
In January, NAFCU, along with other financial services trade associations, sent a letter to Cordray, seeking clarification of the bureau’s “Know Before You Owe” mortgage disclosures rule.
In announcing its intentions in a letter to several trade organizations on April 28, the CFPB advised that they would be looking for input prior to the release of the NPRM.
“The Office of Financial Institutions, along with our Regulations and Markets team, will arrange one or two meetings in late May or early June, but before the NPRM is issued, to discuss further with you the Know Before You Owe rule," the CFPB said in its letter to the associations. "In the meantime, we look forward to continuing to receive your detailed feedback on the implementation of the Know Before you Owe rule.”
The American Land Title Association (ALTA), which has complained for several years that the calculation of title insurance premiums is confusing and inconsistent, championed the CFPB’s efforts to address some of the long-standing issues.
“ALTA’s primary goal for proposed adjustments to TRID (Know Before You Owe) this July is ensuring consumers receive clear information about their title insurance costs on the closing disclosure,” said Michelle Korsmo, ALTA’s chief executive officer. “The current disclosure calculation is inconsistent with the Bureau’s mission to inform consumers about the true costs of their real estate transaction.”
“We have worked closely with the Bureau for over five years on TRID," she added. "We are committed to continuing our conversation with Director Cordray and the CFPB staff to correct the calculation of title insurance policy premiums on the mortgage disclosures this summer. The complexity of TRID makes it difficult for mortgage originators and secondary market investors to determine if they have complied with this massive regulation. ALTA will use this opportunity to work with the CFPB to ease this uncertainty for our members.”
Pete Mills, Senior Vice President of Residential Policy and Member Services for the Mortgage Bankers Association, also commented on the CFPB’s plans.
"MBA is very pleased with CFPB's letter and believes the approach laid out should provide a swift path to issuing a final rule that will give lenders, the secondary market and consumers the clarity and consistency of disclosures the market needs,” Mills said. “In the meantime we appreciate that the Bureau's ‘diagnostic period’ for the Know Before You Owe rule will continue to accommodate good faith compliance efforts. Finally, we look forward to continuing to work with the Bureau on this and other issues in hopes of protecting consumers and strengthening the real estate finance industry."