Tuesday, January 28, 2020
The Consumer Financial Protection Bureau (CFPB) is urging title and settlement agents to help it assess the TILA-RESPA Integrated Disclosures (TRID) rule by participating in a survey.
The CFPB is conducting three surveys in its assessment, including one specifically for closing companies. The bureau said the surveys will help it learn about the experiences of industry participants and better understand the effects of the TRID rule.
The closing company survey “is intended for representatives of institutions that conduct closings for residential real estate transactions that are secured by mortgage loans covered by the TRID rule,” the CFPB stated.
“For the purpose of this survey, an institution that conducts the closing, or settlement, in a real estate transaction may include a law firm, a title company, a settlement company, an escrow company, or any other party providing the service of real estate closing.”
The survey is divided into five sections. The first section deals with closings; the second relates to implementation of TRID; the third section examines costs related to TRID implementation; the fourth section assesses consumer outcomes; and the fifth section examines types/costs of settlement services.
In a January letter to the CFPB, the American Land Title Association (ALTA) noted two aspects of TRID it believes could benefit from further guidance from the bureau.
“First, additional examples of allowable fact patterns for waiver of the three-day waiting period between the delivery of the CD (Closing Disclosure) and consummation would allow lenders to respond to valid concerns of imminent financial harm facing a consumer,” ALTA wrote. “The only example provided in the commentary involves the refinances of a loan to avoid the imminent foreclosure sale of a property.
“Second, additional guidance should be provided to allow settlement agents to use industry standard identification numbers on the Closing Disclosure’s contact information chart. Unlike lenders, settlement agents do not have a nationwide government generated ID number like the Nationwide Multistate Licensing System and Registry.”
In terms of modifying, expanding or eliminating TRID, ALTA wrote: “We believe wholesale changes would be unnecessary. The title industry (and our lender partners) have made significant investments in systems and processes to comply with this regulation and provide a positive closing experience for our customers.”
CFPB requests that each company submit only one survey response. The closing company survey takes 3 to 45 minutes to complete, and responses must be submitted by March 6, 2020. The bureau suggests using a desktop or laptop computer to complete the survey.
You can access the survey here.
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