FinReg + Policy Watch
October 8, 2020

CFPB Releases Assessment of TRID Mortgage Loan Disclosure Rule

On October 1, the Consumer Financial Protection Bureau (CFPB) published a report assessing the Truth in Lending Act and Real Estate Settlement Procedures Act Integrated Disclosure Rule (TRID Rule) and summarizing public comments for modifying, expanding or eliminating the TRID Rule. The report concluded that the TRID Rule:

  • Improved consumers’ ability to find key information, compare terms and costs between initial disclosures and final disclosures, compare terms and costs across mortgage offers, and likely improved consumer understanding of forms;
  • Changed, for a relatively short amount of time, if at all, potential effects on a range of market outcomes (e.g., interest rates and origination volumes) around the TRID Rule’s effective date; and
  • Resulted in sizeable implementation costs for companies and, possibly, increases in ongoing costs.

The CFPB also released a Data Point of 50,000 mortgages, concluding (1) almost 90% of mortgage loans involved at least one revision; (2) 62% received at least one revised Loan Estimate; (3) 49% received at least one corrected Closing Disclosure; (4) the prevalence of changes in loan terms between the first Loan Estimate and the last Closing Disclosure varied greatly across loan terms; (5) APR changes occurred in more than 40% of mortgages; (6) the loan amount and loan-to-value ratio changed in almost 25% of mortgages; and (7) the interest rate changed for 8% of mortgages.

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