Investor Group Seeks CFPB Guidance on TRID

A group of mortgage investors have requested that the Consumer Financial Protection Bureau (“CFPB”) provide additional clarification about investor liability for purchases of loans that fail to comply with the newly implemented Truth in Lending Act (“TILA”) – Real Estate Settlement Procedures Act (“RESPA”) Integrated Disclosure (“TRID”) rules. According to a recent article in National Mortgage News, the investor group sent CFPB Director Richard Cordray a letter on March 30th describing how the ambiguity facing the market as a result of TRID has had a chilling effect on private investment in the U.S. mortgage markets. The authors of the letter write, "We seek formal written guidance clarifying the liability for a violation of each individual TRID requirement, as well as the scope and applicability of TRID's cure mechanisms."

SFIG has made similar requests for additional guidance from the CFPB. SFIG’s draft compliance review proposal, as reported on March 18th, is not intended to supplant efforts to pursue obtaining formal guidance from the CFPB to resolve the current uncertainty related to TRID exceptions. SFIG's proposal is instead being considered and pursued as a concurrent initiative to address the immediate market concerns while SFIG and its members continue to pursue the long term goal to resolve the uncertainty with the CFPB.

Please contact with questions regarding TRID.

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