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CUNA Brings TRID Clarification Requests to CFPB Meeting
Tuesday, June 14, 2016 6:45 AM

Credit Union National Association met with the Consumer Financial Protection Bureau Monday, as part of a listening session hosted by the bureau to hear industry concerns on its mortgage disclosure rule. The CFPB’s Truth in Lending Act-Real Estate Settlement Procedures Act integrated disclosures (TRID) rule went into effect last October, despite numerous concerns raised by CUNA, Cornerstone, and other organizations.

During the meeting, which was attended by CFPB Director Richard Cordray, the Bureau indicated that it favors providing flexibility versus being overly prescriptive and will consider the implications of changes from a vendor perspective.  

Suggestions brought by CUNA to Monday’s meeting include:

  • Clarifying that non-numerical clerical and other nonmaterial errors can be corrected on a Closing Disclosure form for errors on a Loan Estimate form, and expand the errors and cures to allow for other clerical numeric errors;
     
  • Allowing any changed circumstance at any time after the Closing Disclosure is given to be modified. At minimum, the bureau should provide a clear calendar of when changes can be made and charges re-baselined based on the changed circumstances;
     
  • Memorializing the interpretations of various topics, such as lender credits and negative numbers for title insurance, covered in the CFPB’s ongoing webinars to address TRID questions;
     
  • Providing sample forms for constructions lending, including for one-time closes;
     
  • Making the language in the forms and rules consistent with one another; and
     
  • Clarifying that cooperatives are covered and allow time for compliance.