The CFPB released four Frequently Asked Questions relating to the TILA-RESPA Integrated Disclosures rule. The FAQs include the TRID amendment resulting from the 2018 Economic Growth, Regulatory Relief and Consumer Protection Act.
Three questions pertain to corrected closing disclosures and the waiting period before mortgage loan consummation. Certain changes require a credit union to ensure members receive a corrected closing disclosure at least three business days before consummation. Other changes require credit unions to provide a corrected closing disclosure at or before consummation.
The fourth question addresses whether use of a model form provides a safe harbor if the form does not reflect a TRID rule change finalized in 2017. Appendix H to Regulation Z includes blank and non-blank model forms. If a credit union accurately completes the applicable model form, it meets the safe harbor.
To review the CFPB update, visit NCUA’s website.