Last week, the CFPB published a request for information to reassess the integrated mortgage disclosures under the Real Estate Settlement Procedures Act and the Truth in Lending Act. The focus of the assessment is on the November 2013 final rule (“2013 Final Rule”), which took effect on October 3, 2015. While the 2013 Final Rule underwent two additional amendments in July 2017 and April 2018, those amendments are not intended to be the subject of this amendment. However, in its publication, the CFPB indicates, to the extent that inclusion of the 2017 and 2018 amendments makes the assessment of the 2013 Final Rule more meaningful, those amendments may be considered.
The primary goal is to assess the effectiveness of the rule itself. Five goals were included as part of the initial roll out of the TRID rules; two of are included Dodd-Frank Act itself, the remaining three were promulgated by the CFPB. To assess the effectiveness in meeting the stated objectives, the CFPB intends to conduct a cost-benefit analysis; in particular, the plan seeks to quantify the costs and benefits of the TRID rule, with a focus on: (1) Effects on consumers; (2) effects on firms, particularly creditors, settlement service provides, mortgage brokers, consumers, and others; and (3) the effects on markets related to mortgage origination.