ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
Home Uncategorized

Compliance question of the month: May 2026

Under TRID, must the description of a fee or charge be consistent between the Loan Estimate and Closing Disclosure?

May 11, 2026
Reading Time: 1 min read
Compliance question of the month: February 2025

Q Under the TILA-RESPA Integrated Disclose (TRID) requirements, must the description of a fee or charge be consistent between the Loan Estimate and Closing Disclosure?

A Yes. Regulation Z, § 1026.38(h)(4), sets forth the requirements for how creditors must describe or label origination charges, services the borrower did and did not shop for, and other costs on the Closing Disclosure. It states that these services and costs disclosed under § 1026.38(f) and (g) “shall be labeled using terminology that describes the item disclosed, in a manner that is consistent [emphasis added] with the descriptions or prescribed labels, as applicable, used for such items on the Loan Estimate pursuant to § 1026.37.” Further, § 1026.38(h)(4) states that “[t]he creditor must also list the items on the Closing Disclosure in the same sequential order as on the Loan Estimate pursuant to § 1026.37.” Comment -1 to § 1026.38(h)(4) reiterates the requirements regarding the consistency of terminology and the order of the charges.

The consistency in terminology aspect also extends to the written list of settlement service providers. Comment -3 to § 1026.19(e)(1)(vi) explains that the settlement service providers identified on this list “must correspond to the required settlement services for which the consumer may shop, disclosed under § 1026.37(f)(3).” The sample forms in Appendix H of Regulation Z demonstrate this approach, with the sample Loan Estimate H-24(B) and the sample Written List of Providers H-27(B) utilizing the same descriptions of fees and charges.

For more information, contact ABA’s Terry Hollinger.
Please note that this section is not a substitute for professional legal advice.

Tags: ComplianceTILA-RESPA integrated disclosures
ShareTweetPin

Related Posts

Terrorism and money laundering aggregates published: April through June 2024

Terrorism and money laundering aggregates published: July through September 2026

Uncategorized
October 5, 2026

As of Sept. 15, 2026, the 314 Program Office has processed 9,403 requests pertinent to the following significant criminal investigations since the program started in late 2002.

Recent news from Treasury’s Office of Foreign Assets Control: April 5

Recent news from Treasury’s Office of Foreign Assets Control: Oct. 5

Uncategorized
October 5, 2026

News items that are the most recent sanctions-related actions from the Office of Foreign Assets Control.

ABA DataBank: Healthcare led job gains in weaker September report

ABA DataBank: Healthcare led job gains in weaker September report

Economy
October 2, 2026

While the unemployment rate remains relatively low, a continued deterioration in labor market conditions could lead to some weakening in overall credit performance in the months ahead.

ABA files amicus brief urging enforcement of notice-and-continued-use amendments

ABA files amicus brief urging enforcement of notice-and-continued-use amendments

Uncategorized
September 30, 2026

ABA and the Mississippi Bankers Association filed a coalition amicus brief urging the Supreme Court of Mississippi to affirm a Mississippi trial court’s order compelling arbitration and hold that banks may amend deposit agreements, including arbitration clauses, through...

Humboldt Merchant Services agrees to pay $12 million to resolve FTC Act allegations

Humboldt Merchant Services agrees to pay $12 million to resolve FTC Act allegations

Uncategorized
September 30, 2026

Humboldt Merchant Services agreed to pay $12 million to resolve allegations that it violated the FTC Act by opening and maintaining payment processing accounts for merchants that were shell companies or engaged in fraud.

Central District of California denies CashCall’s motion to vacate restitution judgment

Central District of California denies CashCall’s motion to vacate restitution judgment

Uncategorized
September 30, 2026

A California federal court denied CashCall’s motion for relief from a post-remand judgment requiring the company to pay more than $134 million in restitution.

NEWSBYTES

Consumer sentiment falls in October

October 9, 2026

Fed survey finds increase in family income, financial stress

October 9, 2026

FHA formalizes use of alternative credit scoring models

October 9, 2026

SPONSORED CONTENT

The Shift from Demographic Marketing

The Shift from Demographic Marketing

October 1, 2026
Meeting Ag Lending Goals Without Going It Alone

Meeting Ag Lending Goals Without Going It Alone

October 1, 2026
Beyond the Portfolio: The Wealth Manager’s New Role in a Multigenerational World

Beyond the Portfolio: The Wealth Manager’s New Role in a Multigenerational World

September 17, 2026
Banking Technology at a Strategic Crossroads

Banking Technology at a Strategic Crossroads

September 8, 2026

PODCASTS

Podcast: The birth of American money and how it triggered a revolution

October 8, 2026

Podcast: Creating seamless customer experiences

September 30, 2026

Podcast: Telling a different kind of story about community banks

September 28, 2026

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2026 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2026 American Bankers Association. All rights reserved.