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CFPB Addresses Rescission & TRID Rule Waiting Periods & Changed Circumstances in View of COVID-19

Thursday, April 30, 2020   (0 Comments)
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CFPB Addresses Rescission & TRID Rule Waiting Periods & Changed Circumstances in View of COVID-19

 

On April 29, 2020, the Consumer Financial Protection Bureau (CFPB) announced an interpretive rule addressing the waiting periods under the Regulation Z right to rescind provisions and the TRID rule in view of COVID-19, and also whether increases in fees based on COVID-19 constitute a changed circumstance under the TRID rule. The CFPB also issued a compliance aid in the form of a FAQ regarding the ability of a mortgage loan applicant to waive the timing requirement under Equal Credit Opportunity Act (ECOA) and Regulation B provisions.
 
Regarding TRID, "[T]he Bureau is clarifying that (1) if a consumer determines that the extension of credit is needed to meet a bona fide personal financial emergency, (2) the consumer’s brief statement describing the emergency identifies a financial need that is due to the COVID-19 pandemic, and (3) the emergency necessitates consummating the credit transaction before the end of an applicable TRID Rule waiting period or must be met before the end of the Regulation Z Rescission Rules waiting period, then the consumer has a bona fide personal financial emergency that would permit the consumer to utilize the modification and waiver provisions, subject to the applicable procedures set forth in the TRID Rule and the Regulation Z Rescission Rules."
 
CLICK HERE to read more of Rich Andreano's summary.


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