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.
