CFPB Approves Final Rule to Fix TRID’s ‘Black Hole’ Problem

The Consumer Financial Protection Bureau today finalized an amendment to fix a consequential issue with the TILA-RESPA integrated disclosure rules that caused consumers to face significant regulatory delays because of legitimate fee changes during the origination process. It will take effect 30 days after publication in the Federal Register.

The final rule will allow creditors to use either initial or corrected closing disclosures to reflect changes in costs for purposes of determining if an estimate closing cost was disclosed in good faith, regardless of when the closing disclosure was provided relative to consummation — effectively fixing the “black hole” problem that was identified by ABA. It also removes the four-day business limit for resetting tolerances that exists in current law.  These changes are consistent with ABA’s longstanding recommendations on resolving TRID compliance difficulties.