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MReport_Oct2017

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TH E M R EP O RT | 15 COVER STORY TRID 2.0 More Headache Than Help? Instituted to help demystify the mortgage- making process, the newly amended rule's murky mandates and nebulous language have many industry members scratching their heads. T he mere mention of the "TRID" rule can elicit strong reactions from mortgage industry executives and compliance pro- fessionals. The rule can cause their blood pressure to rise, or, on the contrary, it can spark positive feelings associated with having accom- plished a large project successfully. For those of you who have been focused on other parts of the mortgage industry the past few years, TRID is the Consumer Financial Protection Bureau's (CFPB) rule that combined the mortgage disclosures un - der the Truth in Lending Act and the Real Estate Settlement Procedures Act, which was issued in November 2013 and became effective in October 2015 (also known as the TILA-RESPA Integrated Disclosure rule). Clear as Mud? L ately, one of the most talked-about issues with the rule is the CFPB's recent rulemaking to amend it, often referred to as "TRID 2.0," which was issued in July. Although the industry lobbied the CFPB heavily for this amendment rule, many in the industry have mixed feelings about the end result. The CFPB stated that the rule "will generally benefit consumers and industry alike by providing greater clarity for implementation going forward." But there are many areas in which the CFPB's amendments will cause more confusion. In addition, the CFPB did not fix one of the most vexing issues with the TRID rule, the infamous "Black Hole." A Matter of Time O ne important issue for this new rule is its effective date. It is helpful that the industry is not required to comply with TRID 2.0 until Oc- tober 1, 2018. This gives industry about a year to come into compliance with the changes, (this time period is required under the statute, so we can thank Congress for their time). But the CFPB is allowing "optional compliance" beginning October 10, 2017, allowing the industry to implement provi - sions of the rule as it sees fit beginning on that date. The CFPB did not place limits on this op- tional compliance period, and it is not dependent on the application date of a particular loan, which means that lenders can phase in most changes in By Richard Horn

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