Among the items included in the 293-page proposal are tolerance provisions for the disclosed total of payments, making the treatment consistent with pre-TRID practices and paralleling the TRID tolerances for disclosures of finance charges. The bureau would also add commentary facilitating the customary sharing of disclosures with third parties, such as sellers and real estate brokers. The proposal would also partially exempt certain housing assistance loans from TRID requirements and extend the rule’s coverage to all cooperative units.
ABA President and CEO Rob Nichols said:
These proposed changes begin the process of making needed adjustments and clarifications inherent in any large and complex rulemaking. While we don’t anticipate that this proposal will address all of our concerns – and are certain others will arise – we do appreciate the good faith effort made by the CFPB to begin a process for ensuring an improved rule that will benefit all participants in the loan process. We will continue to work with our members and the bureau on further necessary clarifications, adjustments and guidance that will allow us to better serve our customers.
ABA will review the proposal in full and provide comments, which are due Oct. 18.
Read the proposed rule.