AFSA, Trades Comment on TRID RFI

The American Financial Services Association, along with a number of other trade associations, submitted a comment this week (January 20th) in response to a Request for Information (RFI) from the Consumer Financial Protection Bureau (CFPB) regarding its plan for assessing the “Integrated Mortgage Disclosures Under the Real Estate Settlement Procedures Act” (Regulation X) and (Regulation Z), the “Truth In Lending Act Rule” (TRID or TRID).

The comment letter noted the joint trades’ support of the Bureau’s efforts to “gather relevant cost data via structured interviews and surveys with industry participants in order to assess firms' implementation costs and ongoing costs.” The letter noted, however, that this data will be difficult to obtain. In light of the challenges, the letter offers survey data collected by the American Bankers Association alongside TRID implementation.

The comment also included lender-experience information in the context of TRID’s “tumultuous regulatory process.” The trade associations urged the Bureau to make targeted reforms to TRID that benefit all mortgage stakeholders by reducing compliance burdens while also promoting simplicity and clarity in the mortgage process.

The letter includes rationale and appendices over 24 pages and can be reviewed here.