CFPB on Construction Lending under TRID
Clients and Friends,
The Consumer Financial Protection Bureau (CFPB) conducted a webinar on March 1, 2016, in which it addressed questions about how to disclose construction loans under the TILA-RESPA Integrated Disclosure rule (TRID). This was the first webinar since the effective date of TRID and the first guidance from the CFPB specifically addressing construction lending since the rule was issued in November 2013.
The webinar provided basic guidance on how to complete the TRID disclosures for a construction-to-permanent transaction as two separate transactions, or as one single combined transaction. The CFPB did not present any sample disclosure forms. Instead, the CFPB described the regulatory requirements verbally.
The CFPB posts links to the recordings of its TRID webinars, as well as an “index” of questions and answers from its webinars at this link: http://www.consumerfinance.gov/policy-compliance/guidance/implementation-guidance/tila-respa-disclosure-rule//
I have drafted a list of the questions, concise versions of the CFPB’s answers (including quotations as appropriate), and some of my thoughts on several of the CFPB’s answers. Please let me know if you’d like a copy of this document.
