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Joining with the other major trade associations in the real estate industry, NAMB—The Association of Mortgage Professionals is urging the Consumer Financial Protection Bureau (CFPB) to have delayed or restrained enforcement of the new TILA-RESPA Integrated Disclosure (TRID).
"This is not a financial services issue," said NAMB President John Councilman, CMC, CRMS of the letter NAMB authored with 14 other industry trade associations. "We are fully prepared to disclose the fees found in the APR. Our concern is that putting together other parts of the closing three business days prior to closing will cause immense hardship on consumers. The CFPB needs to clarify the responsibilities of lenders for items that may change outside of the financial transaction in which the lender plays no part and has no control. Establishing a changed circumstance and re-disclosing it in the midst of the final days may also create substantial delays depending on how it must be disclosed to certain consumers. Consumers with limited resources are likely to be most adversely impacted by this re-disclosure process since they lack the electronic tools available to more affluent borrowers."
TRID is effective Aug. 1, 2015. The final rule applies to transactions for which the creditor or mortgage broker receives an application on or after that date.
"There are many unresolved conflicts between the responsibilities of lenders and brokers under this rule and state laws," said Councilman. "Inevitably, more will arise when actual transactions begin to take place."
Along with NAMB, the following trade associations joing NAMB in authoring the joint letter to the CFPB: American Bankers Association, American Escrow Association, American Land Title Association, Center for Responsible Lending, Community Mortgage Lenders of America, Credit Union National Association, Housing Policy Council of Financial Services Roundtable, Independent Community Bankers of America, Mortgage Bankers Association, National Association of Federal Credit Unions, National Association of Home Builders, National Association of Realtors, The Realty Alliance and RESPRO.