ALTA Submits Letter to CFPB on TRID "Black Hole"

By American Land Title Association
Oct. 13, 2017

 
ALTA submitted a letter to the CFPB urging the removal of the four-business day limit for resetting tolerances with both initial and corrected Closing Disclosures.

Currently, the rule states that once a lender issues a Closing Disclosure, they are prohibited from issuing any further Loan Estimates. Once the initial Closing Disclosure is sent, the rule proceeds to set out a complex set of timing requirements for issuing updated Closing Disclosures. When a closing delay occurs, some creditors believe they can send the consumer an updated disclosure to reset tolerances while others believe they cannot. The rule states that an updated Closing Disclosure can be used to reset good-faith baselines after a valid changed circumstance in any situation in which a Closing Disclosure has already been issued.
 
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