NAR Recommendations to CFPB’s “Know Before You Owe” Rule

Since the implementation of the TILA-RESPA Integrated Disclosure rule (TRID) on October 3, 2015, the Consumer Financial Protection Bureau (CFPB) has received questions, concerns and complaints regarding various TRID provisions, including those that result in confusion and uncertainty for creditors.

To clear up some of the confusion, the CFPB announced that it will issue a Notice of Proposed Rulemaking on TRID. Required by the Administrative Procedure Act, a Notice of Proposed Rulemaking is simply a public notice issued by law when a United States government agency wishes to add, remove or change a rule of regulation as part of the rulemaking process. In response to the notice, concerned citizens whom the regulation will impact are provided an opportunity to voice their comments.

In an effort to clarify those issues the National Association of REALTORS® (NAR) deems to be of utmost importance, on June 7, 2016, NAR sent a letter to the CFPB requesting that specific written guidance be written into the regulation text, explaining that “reliable, written guidance is critical for effective implementation of the rule.”

Among the more critical changes, NAR is seeking pertain to a real estate professional’s ability to obtain a copy of the Closing Disclosure.

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