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What is TRID?

TRID is The New TILA RESPA Integrated Disclosures. Sections 1098 and 1100A of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) directs the Consumer Financial Protection Bureau (CFPB)to publish rules and forms that combine certain disclosures that consumers receive in connection with applying for and closing on a mortgage loan under the Truth in Lending Act (Regulation Z) and the Real Estate Settlement Procedures Act (Regulation X).

The current Truth-in-Lending disclosure & Good Faith Estimate will be replaces with the new Loan Estimate for most closed-end mortgage loans. While the final Truth-in-Lending disclosure & HUD-1 Settlement Statement will be replaced by the new Closing Disclosure for most closed-end mortgage loans.

What closed-end mortgages loans are excluded from TRID?

  • Open-end credit (HELOCs)
  • Reverse mortgage
  • Mortgage secured by a dwelling that is not real property (i.e., mobile home, house boat)
  • Commercial property, usually more than 1 to 4 residential dwelling unit(s)
  • Lenders who made five or fewer mortgage loans in the preceding calendar year (unless made more than on Home Ownership and Equity Protection Act [HOEPA] loan in any 12-moth period)

What is the effective date of TRID?

Originally the CFPB set the effective date to August 1st, 2015. They have now proposed to delay the effective date to Oct. 3rd. The final rule applies to transactions for which the creditor or mortgage broker receives an application on or after that date.

Can I use the new disclosure forms before the effective date?

No. Use of the forms prior to the effective date is prohibited.

What is the definition of a business per TRID?

There are two different definitions of a business day for TRID.

  • In regards to the loan estimate a business day is defined as all calendar days on which the creditor’s office are open to the public for carrying out substantially all of its business functions
  • In regards to the closing disclosure and business day is defined as all calendar days except Sundays and the legal public holidays specified in 5 U.S.C. 6103(a)

What are the new timing requirements of TRID?

Each new form has different timing requirements. The lending institution is responsible to provide the consumer with the loan estimate no later than 3 business days from receipt of application. The loan application must be delivered no later than 7 business days prior to consummation of the loan. While the closing disclosure must be delivered to the consumer no later than three business days prior to consummation.

Where can I find more information?

http://www.consumerfinance.gov/regulatory-implementation/tila-respa/

http://www.alta.org/cfpb/index.cfm

http://www.eventbrite.com/o/rainier-education-4388921891


Only the rule and its Official Interpretations can provide complete and definitive information regarding requirements. For the complete rule and other materials about the final rule.

http://files.consumerfinance.gov/f/201311_cfpb_final-rule-preamble_integrated-mortgage-disclosures.pdf

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