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TRID Advocacy

Overview

ALTA has advocated for its members the Consumer Financial Protection Bureau's (CFPB) final regulation for Truth-in-Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) Integrated Disclosures (TRID). TRID disclosures are required to be used on most residential mortgage transactions after October 3, 2015. A Loan Estimate will replace the current Good Faith Estimate (GFE) and early TIL disclosure, while a Closing Disclosure will replace the HUD-1 and final TIL disclosure.

Impact to the Industry

ALTA members will need to comply with these new disclosure requirements, which will require the title and settlement industry to go through one of the largest and most costly regulatory changes in its history.

Compliance with this regulation will require more than simply updating our systems for two new disclosure forms – it requires a paradigm shift in the way real estate settlements occur in the United States.

TRID Compliance – resources for how to comply with TRID

ALTA Policy Statement

ALTA Board Statement on ALTA's priorities (adopted February 2015):
"In 2015, the Board of Governors of the American Land Title Association will work with Congress and the Administration to: (1) ensure implementation of TILA/RESPA Integrated Disclosures is as smooth as possible and improve how the CFPB works with ALTA members; (2) promote responsible reform of our nation's housing finance; (3) improve FHA's onerous rules for title clearance of REO property and condo eligibility; and (4) advocate on tax policies important to ALTA's small business members and their real estate customers."

ALTA Policy Statement on Real Estate Closings (adopted February 2013):
"It is the position of the American Land Title Association that the single best way to protect consumers in a real estate and mortgage transaction is to maintain the traditional role of the trusted, third-party settlement agent at closing."

ALTA Congressional Testimony

TILA-RESPA Integrated Disclosure: Examining the Costs and Benefits of Changes to the Real Estate Settlement Process (Housing and Insurance Subcommittee of the House Financial Services Committee)

Diane Evans - May 14, 2015

Regulatory Burdens to Obtaining Mortgage Credit (United States Senate Committee on Banking, Housing & Urban Affairs)

April 16, 2015 - Statement for the Record

Examining Regulatory Burdens on Non-Depository Financial Institutions (Financial Institutions and Consumer Credit)

Diane Evans - April 15, 2015

Legislative Proposals to Improve Transparency and Accountability at the CFPB (House Financial Services Committee Subcommittee on Financial Institutions and Consumer Credit)

Rob Chapman - May 20, 2014

"Who's In Your Wallet: Examining how Washington Red Tape Impairs Economic Freedom (House Financial Services Subcommittee on Financial on Financial Institutions and Consumer Credit)

April 8, 2014 ALTA Statement for the Record


ALTA Advocacy

June 16, 2015: ALTA Statement on Proposed TRID Delay

June 9, 2015: Joint trades letter to Rep. Hensarling and Rep. Waters on H.R. 2213

May 14, 2015: ALTA President Diane Evans written testimony before House Committee on Financial Services

May 14, 2015: ALTA Lobby Day Leave Behind

May 5, 2015: Joint trades letter to Rep. Pearce and Rep. Sherman on H.R. 2213

April 30, 2015: Meeting request to Director Cordray from ALTA President Diane Evans

April 27, 2015: H.R 2213

April 16, 2015: ALTA Statement for the Record for Banking hearing on Regulatory Burdens to Obtaining Mortgage Credit

April 15, 2015: ALTA President Diane Evans written testimony before House Committee on Financial Services

March 18, 2015: Letter to CFPB Director Richard Cordray on TRID

November 10, 2014: ALTA comment letter on CFPB timing for issuing disclosures

September 16, 2014: Joint trades letter to CFPB Director Richard Cordray on TRID implementation

April 8, 2014: ALTA Statement for the Record for Financial Services Subcommittee on Financial Institutions and Consumer Credit hearing entitled, "statement for the record for this hearing entitled "Who's In Your Wallet: Examining How Washington Red Tape Impairs Economic Freedom."

May 15, 2013: Joint Trades letter thanking Rep. Perlmutter for Dear Colleague letter to CFPB

May 15, 2013: Joint Trades letter thanking Rep. Stivers for Dear Colleague letter to CFPB

November 6, 2012: ALTA Comment letter to CFPB on proposed TRID regulation

October 11, 2012: Meeting request with Richard Cordray from ALTA President Frank Pellegrini

April 16, 2012: Joint Trades RESPA-TILA Integration Comment Letter to the CFPB


News about ALTA's TRID Advocacy

May 27, 2016 'CFPB Bullied Me' into $85K Settlement: Former Wells Fargo Officer
National Mortgage News | May 26, 2016
The CFPB alleges that David Eghbali, a loan officer for a Wells Fargo branch in Beverly Hills, Calif., developed a scheme to manipulate escrow fees in order to close more mortgages and boost his bonus.
May 26, 2016 Take Action to Help Fix TRID
U.S. Reps. Dennis Ross (R-FL) and Ed Perlmutter (D-CO) have drafted a bipartisan letter supporting ALTA’s efforts to fix the inaccurate disclosure of title insurance premiums on the TILA-RESPA Integrated Disclosures). Take action today and encourage the CFPB to change the inaccurate disclosure of title insurance premiums. Consumers deserve clear information about their title insurance costs.
May 26, 2016 ALTA Asks CFPB to Support Best Practices
To help provide clarity and guidance to supervised entities, ALTA sent a letter to the Consumer Financial Protection Bureau asking the bureau to announce support of the association’s Title Insurance and Settlement Company Best Practices.
May 24, 2016 Now It's Real — No Statute of Limitations for CFPB UDAAP Claims
Reuters | May 23, 2016
The Consumer Financial Protection Bureau believes that no statute of limitations applies when it sues parties in its administrative tribunal, as opposed to federal court.
May 19, 2016 Industry Compliance: Understanding Regulator Interpretations and Trends in Enforcement
Some have called compliance the “new black.” That may be partially correct, but complying with laws and regulations has never gone out of style. What has changed, though, is the lens through which regulators are using to interpret compliance. With the Consumer Financial Protection Bureau on the beat, regulators are laser-focused on the consumer experience. Read on to learn how the CFPB and other regulators are viewing compliance with the Real Estate Settlement Procedures Act, including violations for affiliated business arrangement disclosures, payment of referral fees and marketing service agreements.
May 19, 2016 Congressman Calls for Regulatory Transparency from the CFPB
DS News | May 18, 2016
U.S. Rep. French Hill (R-Arkansas) said Monday that the Consumer Financial Protection Bureau (CFPB) needs to do a lot more to ensure the industry understand the new TRID-compliant ‘Know Before You Owe’ rules before they take effect. Specifically, Hill wants to make sure that the Bureau clears up confusing language regarding insurance fees in the mortgage process.
May 18, 2016 Is TRID Encouraging Smarter Homebuyers?
National Mortgage Professional Magazine | May 17, 2016
According to the new Home Closing Survey conducted by the American Land Title Association (ALTA), 92 percent of surveyed homebuyers set aside time before their closings to review their mortgage documents.
May 17, 2016 ALTA Provides Congress Feedback About TRID Implementation, Continued Challenges
ALTA last week sent a letter to U.S. Reps. Blaine Luetkemeyer (R-MO) and Randy Neugebauer (R-TX) describing how the industry is adapting to the TILA-RESPA integrated Disclosure (TRID) rule and how Congress can support a smoother implementation process.
May 17, 2016 ALTA Closing Survey Shows More Consumers Reviewing Mortgage Disclosures
According to the survey, the CFPB’s Know Before You Owe regulation has resulted in closings being delayed slightly, but highlights the need for collaboration among title/settlement agents, Realtors and lenders to educate consumers about the transaction.
May 17, 2016 More Homebuyers Reviewing Mortgage Documents Under TRID
HousingWire | May 16, 2016
“Title and settlement agents went to great lengths to prepare and train staff prior to implementation of the regulation,” said Michelle Korsmo, ALTA’s chief executive officer. “The hard work of these professionals paid off as 92% of surveyed homebuyers are taking time to review their mortgage documents before the closing,”
More CFPB Articles
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American Land Title Association
1800 M Street, NW, Suite 300S
Washington, D.C. 20036-5828
P. 202.296.3671 F. 202.223.5843
www.alta.org
service@alta.org
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