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More TRID FAQs released
The CFPB Thursday released a new set of FAQs under the TILA-RESPA Integrated Disclosure (TRID) rule, specifically related to providing loan estimates to consumers. NAFCU has worked with the bureau to obtain more guidance for credit unions on this rule, and one of the new FAQs confirms the association's interpretation of when a loan estimate is triggered.
Access the five new questions here. The bureau notes that reviewing these questions and answers is not a substitute for reviewing TILA, RESPA, Regulation Z or its official interpretations.
Earlier this year, NAFCU requested more clarity and assistance for credit unions on: cure provisions and error corrections, negative owner's title insurance premium, calculating cash to close, second lien loans, pre-approvals/pre-qualifications and payoff in a purchase money loan. The association also met with the Bureau as it begins its assessment of the rule and will continue to seek more guidance on unclear aspects of the rule.
NAFCU has various resources available on TRID, including two popular blogs: One that explains the bureau's fix to the TRID "black hole," and another detailing "TRID 2.0" compliance deadline related to statutory damages and errors in loan estimate or closing disclosure.