Since then, the CFPB published additional clarifications to Regulation Z in 2017. Additionally, in 2018, the CFPB published an amendment to the earlier TRID Rule, which provided clarifications around the so-called “black hole” timing requirements of the Loan Estimate and the Closing Disclosure. Finally, it also includes a limited number of updates related to regulatory changes resulting from the passage of S. 2155 in 2018.
The underlying premise of this documentation remains the same: to establish a best practices approach to pre-securitization testing logic that will drive the due diligence conducted by TPRs. However, the conclusions set forth in the document do not necessarily reflect how courts and regulators, including the CFPB, may view liability for TILA violations, presently or in the future. The Structured Finance Association and its membership continue to work with the CFPB toward the goal of providing formal guidance for the benefit of the consumer, primary, and secondary mortgage markets.
The TRID Compliance Review Scope is available at no cost to individuals of Structured Finance Association member firms, or for purchase by non-members. The TRID Compliance Review Scope will continue to be reviewed and updated by the Association and is subject to the same protocols as other Association work streams and work product.
Click here to see sample of the Structured Finance Association’s TRID Compliance Review Scope. In order to receive a free copy of the most recent TRID Grid, please email [email protected].