Updated TRID Small Entity Compliance Guide

The CFPB released version 5.0 of the TILA-RESPA Integrated Disclosure Rule Small Entity Compliance Guide.

The revised version incorporates the recent amendments to the rule that became effective on October 10, 2017.  Compliance with the amendments will be required for applications received on or after October 1, 2018.

Updates to the Guide include:

• requirements and guidance on current requirements for tolerances in the good faith analysis (Section 7)
• requirements and guidance for providing revised Loan Estimates (Section 8)
• requirements for permitting a consumer to shop and providing the written list of service providers (Sections 7.3, 7.5, 7.6, 7.7, 7.11, and 8.7)
• coverage for cooperative units, trusts, and the partial exemption for certain housing assistance loans (Section 4)
• guidance on lender and seller credits, including impacts to the good faith analysis (Sections 7.13 and 13.10)
• tolerance standards applicable to the Total of Payments (Sections 10.11) guidance on disclosing transactions with a simultaneous subordinate-lien loan (Sections 10.8, 11.5, and 13.9)
• requirements for providing corrected Closing Disclosures for changes to per diem interest (Section 12.7)
• disclosing cures for tolerance violations (Sections 7.14, 10.13, 12.10)
• guidance on sharing disclosures with third parties (Section 13.8)
• guidance on construction loans
• the safe harbor provided by correct use of sample forms (Sections 5.2 and 10.3)
• updated effective date requirements for 2017 amendments (Section 1 and 3)
• standardization of coverage of cooperative units throughout.

Included in version 5.0 are changes incorporated into version 5.1 regarding disclosure of specific seller credits (Section 13.10).