To paraphrase Dinah Washington: What a difference a word makes. The Consumer Financial Protection Bureau (CFPB), with none of its usual media fanfare, quietly corrected the TILA/RESPA Integrated Disclosure (TRID) rule by inserting a missing word that impacted the question of property taxes.
As originally published in the Federal Register in December 2013, the CFPB’s rules stated that “property insurance premiums, property taxes, homeowner's association dues, condominium fees, and cooperative fees … are subject to tolerances whether or not they are placed into an escrow, impound, reserve, or similar account.”
However, a small but crucial word was missing—the text was supposed to read “are not subject to tolerances whether or not they are placed into an escrow, impound, reserve, or similar account.”
The correction was published in today’s Federal Register and goes into immediate effect. The CFPB made no public acknowledgment of its error on its Web site.