NAFCU Services Blog

By: Andy Dunn, Senior Attorney, Wolters Kluwer 

Recently the Consumer Financial Protection Bureau (CFPB) released its notice of proposed rulemaking for the Know Before You Owe rule, commonly referred to as TILA-RESPA Integrated Disclosures (TRID). In their press release, the CFPB emphasized four changes: 1) Tolerances for the total of payments; 2) Housing assistance lending; 3) Cooperatives; and 4) Privacy and sharing of information, along with minor corrections across several topic areas.

It’s great to have the CFPB working to formalize the nonbinding verbal guidance it has provided to industry stakeholders, including Wolters Kluwer. The proposed rule helps eliminate the risk, especially in a presidential election year, that nonbinding verbal guidance could lead to future compliance violations following a change in bureau leadership. Once the proposed rule changes are finalized and published, all industry participants will be working from the same playbook.

In working closely with our customers to help them comply with the Know Before You Owe rule, especially around areas where nonbinding verbal guidance from the CFPB was required, we’ve found the most recurring trouble spots came from financial calculations. From the CFPB’s proposed changes it appears many of these areas, including calculating cash to close table; principal reduction/curtailment; summary of transactions table; and escrow account disclosures will be addressed. This is great news for our customers and partners, as many of these calculations are complicated to produce under the current rule.

Wolters Kluwer kicked off its 2016 User Summits and workshops with their ComplianceOne mortgage customers in Bloomington, Minnesota on August 9. The events are being held in 18 U.S. cities, ending in San Antonio, Texas on December 8, 2016. The Summits will provide a great opportunity for ComplianceOne mortgage customers to discuss the proposed rule changes with peers and to share their feedback if they think additional guidance is needed beyond what has been proposed.

Wolters Kluwer is looking forward to responding to the CFPB’s proposal and sharing their customers’ feedback with the bureau. The comment period closes October 18, 2016.

Wolters Kluwer is the NAFCU Services Preferred Partner for Consumer and Member Business Lending & Deposit Services. Learn more at www.nafcu.org/wolterskluwer.