Your comprehensive guide to CFPB’s newest TRID compliance updates

by James McClister

Completing the Loan Estimate and Closing Disclosure

Added sub sections

  • Section 5.3 – How must a creditor complete (i.e., insert information into) the Loan Estimate form?
  • Section 10.4 – Are creditors required to use any particular method to complete (i.e., insert information into) the Closing Disclosre form?

Formatting the Loan Estimate and Closing Disclosure

Added sub sections

  • Section 5.6 – If there are more or fewer charges in a category of costs, can a creditor change the number of lines for that category? (§§ 1026.37(f)(6) and 37(g)(8))
  • Section 5.7 – Can the designation “N/A” be used where no value is to be disclosed for a cost? (Comment 37-1)
  • Section 10.11 – What should be done if the information required to be disclosed does not fit in the space allotted on the Closing Disclosure form?
  • Section 13.3 – Is there a required naming convention used for charges on the Loan Estimate or Closing Disclosure?
  • Section 13.4 – How does the creditor disclose charges for third-party administrative and processing fees?

Delivery requirements for the Loan Estimate and the special information booklet

Added sub sections

  • Section 6.5 – How must the Loan Estimate be delivered? (§ 1026.19(e)(1)(iv))
  • Section 15.7 – If a creditor makes the Toolkit available on its website, does that satisfy the rule’s delivery requirement?

Requirements upon receiving an application

Added sub sections

  • Section 6.7 – What if a creditor receives these six pieces of information, but needs to collect additional information to proceed with an extension of credit? (Comment 2(a)(3)-1)
  • Section 6.9 – May an online application system refuse to accept applications that contain the six elements of an application because other preferred information is not included? (§ 1026.2(a)(3))
  • Section 6.10 – If the six pieces of information exist in the creditor’s system or its file, does that trigger the requirement to provide a Loan Estimate? (§ 1026.2(a)(3))
  • Section 6.11 – Can a creditor review detailed written documentation of income and assets prior to delivering a Loan Estimate? (Comment 2(a)(3)-1)

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