CFPB Updates TRID Rule FAQs to Address Construction Loans

June 4, 2019

The Consumer Financial Protection Bureau on May 31 updated its TILA-RESPA Integrated Disclosure (TRID) rule FAQs to address construction loans.

In the first FAQ, the CFPB confirms that the TRID rule applies to most construction-only and construction-to-permanent loans.

In the second FAQ, the CFPB confirms the existence of certain Regulation Z provisions that address construction loans. The provisions are (1) section 1026.17(c)(6), which provides for the ability of a creditor to treat a construction-to-permanent loan as one or multiple transactions, (2) Appendix D, which provides guidance on how to calculate certain disclosures with construction loans, and (3) section 1026.19(e)(3)(iv)(F), which permits a creditor to issue a revised Loan Estimate with a loan on new construction when settlement is expected to occur more than 60 days after the original Loan Estimate is provided.

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