Moody’s: SFIG TRID Proposal Adequately Addresses Risk

According to a recent report from Moody’s Investors Service, SFIG’s draft proposal on a standardized approach to the scope of review for TILA-RESPA Integrated Disclosure (“TRID”) exceptions “is adequate to identify those compliance risks that are likely to cause losses to residential mortgage-backed securitization (RMBS) trusts, aside from one grading provision with which [Moody’s] disagree[s].” As SFIG noted in its announcement of the proposal in March, this draft assumes TRID is interpreted by regulators and courts in accordance with the principles of liability set forth in a December 29, 2015 letter from Richard Cordray, the Director of the CFPB. Consequently, Moody’s notes that some of the proposal’s legal positions are subject to uncertainty pending additional guidance from the CFPB. However, Moody’s concludes that the CFPB’s decision to re-open TRID will likely benefit SFIG’s efforts to standardize compliance with the rulemaking.

Please contact with questions regarding TRID.

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