With the TRID 2.0 changes finalized and changes to address the ‘Black Hole’ out for comment, some in Congress are already looking at additional upgrades to the Rule.
A Bill sponsored by Representative French Hill (R /AK) was introduced for discussion in the Financial Institutions and Consumer Credit Subcommittee of the House Financial Services Committee. Try and say that one fast.
The Bill, dubbed the TRID Improvement Act of 2017 (TRIDIA), is aimed at assisting lenders and consumers by providing better clarity in disclosure and more time for correction of bona fide errors.
Two issues, specifically addressed in the proposal, which are of great interest to the mortgage industry are:
- An extension of the time to cure a fee violation from 60 to 210 days after consummation, and
- Amend RESPA to allow for the disclosure of title policy premiums to include the calculation of any simultaneous issue discounts.
The industry has been clamoring for these changes as they believe they will help both lenders, through more accurate title fee disclosure, and consumers, providing a better understanding of the title premium charges.
The extension for a cure would take some of the pressure off of the lenders when disclosing fees and trying to get consumers to their closings on time while allowing loan purchasers a little more time for their reviews.
Lenders can take the time to more carefully review their loans after consummation to make any needed corrections and rebate overpaid fees when necessary.
The extended time will also allow loan purchasers the time to review loans to detect any violations so the delivering lender may issue the amount for any cure allowing for the loan’s purchase or avoid a repurchase.
This is some good stuff. Hopefully, it will be addressed and passed by the Committee and introduced into the House and then on to becoming revisions to the law. But wait, there’s more…
Representative Claudia Tenney (R/NY) also introduced to the Committee a Bill that would to amend some escrow rules under RESPA. This one is titled the “Community Institution Mortgage Relief Act of 2017.” (Maybe the CIMRA).
This one would exempt creditors with assets of $50 billion or less from the requirements to establish an escrow account for first lien principle dwelling loans. It would also require the CFPB to exempt servicers of 30,000 or fewer mortgages from certain loan servicing and escrow account administration requirements.
Some in Congress believe the new TRID rules are a little too restrictive and these have resulted in impeding lenders in their willingness and ability to offer and provide consumers with the needed services to satisfy their home financing needs. You don’t say!
So, whether it’s TRID 3.0 or TRIDIA, or something else they come up with, more changes are needed to the CFPB’s “Know Before You Owe” rules. These are a good start.