CFPB Recognizes “Know Before You Owe Rule” Needs Clarity

Ronda Guzman

Consumer Mortgage Loan Compliance Specialist

May 17, 2016

Consumer Financial Protection Bureau (CFPB) Director, Richard Cordray has announced in a letter dated April 28, 2016, that the Bureau will be issuing a formal notice in late July of accepting public feedback on the TILA-RESPA Integrated Disclosure (TRID) rule – also known as the “Know Before You Owe Rule.”

Cordray’s letter states that “the implementation of the ‘Know Before You Owe Rule’ poses many operational challenges.” The CFPB “also recognizes that implementation is particularly challenging because of the diversity of participants, from small to large financial institutions, mortgage brokers, real estate brokers, etc.”  The letter further explains that, “there are places in the regulation text and commentary where adjustments would be useful for greater certainty and clarity.”

If you would like to read the entire letter you can do so here.

The news is welcome, and we believe the financial community will be optimistic about receiving some much needed clarity from the CFPB on both Loan Estimates and Closing Disclosures.

As our firm conducts TRID reviews, we find that most errors are simple, technical errors caused by the bank or lender being unsure of the placement of a fee or the wording required on the form.  Some may have also noticed that the CFPB recently redesigned their website and I, for one, had a lot of links to TRID information which stopped working with the new change.  If you lost yours too, here is the link to the CFPB’s page that will lead you to all of the TRID resources. Hopefully this will help when you’re not sure of where a certain fee should go or what wording is required!

If you have any further questions, please contact Ronda Guzman, PKM Consumer Mortgage Loan Compliance Specialist at rguzman@pkm.com or 404-420-5678.