TRID – Possible Changes by CFPB
Appraisers / Lenders, the Bureau of Consumer Financial Protection (CFPB) has opened a comment period soliciting written comments on the current TILA-RESPA Integrated Disclosure (TRID) process applying to consumer mortgage loans.
Comments can be submitted to the following addresses, until Jan. 21, 2020. You may submit comments, identified by Docket No. CFPB-2019-0055, by any of the following methods:
- Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments.
- Email: 2019-RFI-TRID@cfpb.gov. Include Docket No. CFPB-2019-0055 in the subject line of the email.
- Mail/Hand Delivery/Courier: Comment Intake – TRID Assessment, Consumer Financial Protection Bureau, 1700 G Street, NW, Washington, DC 20552
Read more in this PDF accessed here.
For appraisers and lenders, a key sticking point is the ‘appraisal fee’ has been hard-fixed, quoted up front, and difficult to change, at the time the assignment is given to the appraiser. Once the appraiser gets to the property, other characteristics or issues (typically unknown in advance) can arise which may cause the appraiser to believe a fee increase is necessary to compensate the additional time spent during report preparation. This causes a lot of heartburn with lenders, because the TRID mortgage application procedure has to start over, delaying the lending process.
But there are legitimate reasons why the appraisal fee needs to be uncoupled from the other hard-fixed fees.
Also, in TRID, there is no mandated instruction saying the appraisal fee must be shown separately from any other ‘management fee’ associated with the assignment, i.e. AMC processing fee, etc.
Any fees applying to the appraisal should be itemized so that the consumer has full understanding of what they are paying for.
If you agree with these points, or have other comments, send your written items to the CFPB per one of the methods above.