Wednesday, February 10, 2016

CFPB corrects error in TRID rule
Falls victim to the dreaded 'typographical' error

It’s been four months since the implementation of the Consumer Financial Protection Bureau’s TILA-RESPA Integrated Disclosures rule in October shook up the housing industry, and many in the industry are still getting used to the new normal.

But, starting Wednesday, there’s a small portion of the TRID rule that will be changing, thanks to a “typographical error” in the supplementary information provided by the CFPB.
The change was spotted via TheHill.com, which listed several changes to the Federal Register that will be published on Wednesday.

One of those changes is to the CFPB’s TRID rule.

According to the CFPB’s addendum, the supplementary information to the TILA-RESPA Final Rule, which was released in 2013, contained a typographical error.

The addendum to the Federal Register and the TRID supplementary information corrects the error, which deals with the application of tolerances to property insurance premiums, property taxes, homeowner’s association dues, condominium fees, and cooperative fees.

According to the CFPB’s addendum, which can be read here, on page 79829 of Volume 78 of the Federal Register, the supplementary information states that “property insurance premiums, property taxes, homeowner’s association dues, condominium fees, and cooperative fees” are “subject to tolerances,” when it should read that those fees are “not subject to tolerances.”

The CFPB’s addendum states that the error, listing the fees as “subject to tolerances,” is inconsistent with the sentence that precedes it, which reads: “Property insurance premiums are included in the category of settlement charges not subject to a tolerance, whether or not the insurance provider is a lender affiliate”

Additionally, the CFPB addendum states that on page 79829 of the Federal Register, several lines will be revised from “are subject to tolerances whether or not they are placed into an escrow, impound, reserve, or similar account” to read “are not subject to tolerances whether or not they are placed into an escrow, impound, reserve, or similar account”.
Click here to read the CFPB addendum in full.

The changes go into effect upon publication in the Federal Register, which is scheduled to take place on Wednesday.

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