CFPB Provides TRID Guide for Real Estate Agents

August 20, 2015

The Consumer Financial Protection Bureau (CFPB) on Aug. 14 released TRID resources to help real estate professionals prepare consumers for the new closing process.

The guide includes five sections:

To help prepare consumers, the CFPB said real estate agents should:

  • Promote open lines of communication to ensure everyone has accurate and updated information.
  • Ask who will provide the Closing Disclosure and what their process will be for delivering it and making changes.
  • Encourage clients to make decisions about their mortgage options early in the process and stick to them, since late changes could cause delays.

The CFPB also highlighted the fact that most changes on the Closing Disclosure will not require the lender to give the buyer three more business days to review the new terms before closing. The three changes requiring a new three-day review period include:

  • The APR (annual percentage rate) increases by more than 1/8 of a percent for regular loans (most fixed-rate loans) or 1/4 of a percent for irregular loans (most adjustable loans). A decrease in APR will not require a new three-day review if it is based on changes to the interest rate or other fees. Lenders have been required to provide a three-day review for these changes in APR since 2009.
  • A prepayment penalty is added, making it expensive to refinance or sell.
  • The basic loan product changes, such as a switch from fixed rate to adjustable interest rate or to a loan with interest-only payments.

The following are examples of circumstances that do not require a new three-day review:

  • Unexpected discoveries on a walk-through such as a broken refrigerator or a missing stove, even if they require seller credits to the buyer.
  • Most changes to payments made at closing, including the amount of the real estate commission, taxes and utilities proration, and the amount paid into escrow.
  • Typos found at the closing table.

Contact ALTA at 202-296-3671 or