Three of the initiatives by the Consumer Financial Protection Bureau (CFPB) that have had the biggest impact on the mortgage industry—the TILA-RESPA Integrated Disclosure (TRID) rule (a.k.a. the Know Before You Owe, or KBYO rule), the updated Home Mortgage Disclosure Act (HMDA) rule, and the August 2016 updates to the mortgage servicing rules were highlighted in a report on the Bureau’s activities from Q4 2015 to Q3 2016.
In its recently-released fourth report to the House and Senate Committees on Appropriations coving October 1, 2015, through September 30, 2016, the Bureau laid out some of the materials and helps it provided during that 12-month period to assist institutions implement those three initiatives.
“As the Bureau has issued regulations to implement Dodd-Frank Act requirements, it has focused intently on supporting the implementation process for these rules with both industry and consumers,” CFPB stated in the report. “The Bureau has provided substantial implementation support for these regulations, including engaging in public outreach, speaking at conferences, and publishing guides, summaries, charts, webinars, and other resources.”
The implementation of TRID, which went into effect on October 3, 2015, caused no small amount of consternation among mortgage lenders and other stakeholders in the industry. Among the helps the CFPB has provided are several implementation resources that include a plain-language guides containing an overview of TRID’s key aspects, illustrated instructions on how to complete the new Loan Estimate and Closing Disclosure Forms. The Bureau has also conducted several public webinars on TRID to answer specific questions on the implementation and/or interpretation of the rule’s requirements the Bureau has received since the rule went into effect.
In July 2016, the Bureau proposed updates to TRID aimed at providing greater clarity and certainty surrounding the rule.
“The proposed changes would augment implementation of the KBYO rule, which took effect in October 2015, and further help to facilitate compliance within the mortgage industry,” CFPB stated. “Bureau staff continues to engage in outreach and market monitoring activities to identify implementation issues as they arise, and provide informal oral guidance in response to interpretive inquiries from a myriad of stakeholders.”
The CFPB issued its updated HMDA rule in October 2015 along with resources to help industry stakeholders understand and implement the new rule, including a summary and overview of the final rule, a timeline of the rule’s effective dates, coverage charts for financial institutions to determine if they are HMDA reporters, a summary of reportable data explaining the HMDA data points that are to be collected, recorded, and reported per the updated rule, a compliance guide with a plain-language explanation of the rule, a webinar with an overview of the final HMDA rule, and a number of data submission resources for HMDA filers available on the CFPB’s website.
“In addition to publishing implementation resources, the Bureau continues to engage in extensive outreach activities, including speaking at conferences and other events, to support the implementation of new HMDA mortgage lending data reporting rules and to identify and address implementation issues,” the Bureau said.
The CFPB published a number of resources along with the August 2016 updates to its mortgage servicing rules, including a summary of the new rule, a fact sheet, and a table summarizing how the rule affects small servicers, and a fact sheet explaining the definition of “delinquency” under the new rule and how the new rule applies to TILA-RESPA requirements.
“The Bureau plans provide additional support to facilitate implementation and compliance with the August 2016 amendments to the mortgage servicing rules, and to update the existing compliance guide to reflect the August 2016 amendments,” the CFPB wrote in the report.
Click here to view the CFPB’s full report.