CFPB Issues TRID FAQ on Build Act Partial Exemption

May 20, 2021

The Consumer Financial Protection Bureau (CFPB) on May 14 issued an update to its TILA-RESPA Integrated Disclosure (TRID) rule FAQs to address a partial exemption added by the Building Up Independent Lives and Dreams Act (BUILD Act) that became law in January 2021.

Regulation Z of TILA includes a partial exemption from the Loan Estimate and Closing Disclosure requirements of the TRID rule for subordinate housing assistance loans that met certain conditions. The BUILD Act added a partial statutory exemption from such requirements for similar transactions. The FAQs provide that to qualify for the BUILD Act partial exemption, a transaction must meet all of the following criteria:

  • The loan must be a residential mortgage loan.
  • The loan must be offered at a 0 percent interest rate.
  • The loan must only have bona fide and reasonable fees.
  • The loan must be primarily for charitable purposes and made by an organization described in Internal Revenue Code section 501(c)(3) and exempt from taxation under section 501(a) of that Code.

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