CBA Requests Further Clarification on TRID Requirements

On Friday, January 29, 2016, CBA President and CEO Richard Hunt joined other banking trade heads in sending a letter to CFPB Director Richard Cordray requesting further clarification on TILA-RESPA Integrated Disclosure (TRID) requirements. The letter was in response to a December 29, 2015 communication from Director Cordray stating banks may correct minor errors and oversights on disclosure forms.


The trades stated, “While the December 29 letter is helpful, many lenders, investors, due diligence firms, and other compliance experts still report . . . they cannot fully rely on its contents unless it is published as official CFPB guidance. Absent such action, liquidity in key portions of the market will remain threatened, damaging consumer access to affordable credit and the viability of key mortgage channels and businesses. For this reason, we strongly urge the CFPB to publish the substance of the December 29 letter in the Federal Register… [to] provide entities greater confidence to correct errors for the larger purpose of preserving liquidity in the system and affordable loans for consumers.”


The groups expressed concern with the “good faith” period coming to a close as critical compliance questions still remain. They requested the CFPB form an internal Know Before You Owe Task Force of key staff to engage with stakeholders to identify remaining compliance problems and help the CFPB prioritize and select the best solutions.