Now that the Consumer Financial Protection Bureau announced it opened the comment period for updating the TILA-RESPA Integrated Disclosure rule, a key concern with the rule that the American Land Title Association has long addressed can finally be dealt with.
ALTA held its annual Lobby Day on May 18, hosting more than 250 land title professionals on Capitol Hill to ask members of Congress to sign this letter authored by Reps. Dennis Ross, R-FL, and Ed Perlmutter, D-CO. Seventy-four members of Congress have already signed the letter.
From the letter:
One area the CFPB should address in this NPRM is to fix the rule’s requirement that is causing consumers to receive incorrect title insurance premium disclosures. In the majority of States across the country, consumers are not receiving an accurate disclosure on their title insurance premiums. In these States, CFPB is not allowing for the calculation of a discounted rate known as “simultaneous issue,” which is a rate title insurance companies provide to consumers when they purchase a lenders and owners title insurance policy simultaneously. This rate provides consumers with an effective discount on their owners title policy in order to protect their property rights for as long as they own their home. This NPRM is a great opportunity to fix this issue and ensure that your new forms serve as a credible source of accurate information about the true costs of buying a home for consumers.
Since the rule went into effect on Oct. 3, a slew of issues ranging from small to large have cropped up. And after a lot of pushback from the industry, the CFPB said it would take another look at the Know Before You Owe rule, answering calls to make official a lot of the informal guidance given by the bureau.
The bureau said it hopes to issue the NPRM in late July and looks forward to comments and feedback on it.
Up until this point, the industry has been continuously told that “examiners will be squarely focused on whether companies have made good-faith efforts to come into compliance with the rule.”
In the April issue of HousingWire Magazine, John Hollenbeck, president of ALTA, addressed issues with TRID in a commentary titled “The key to solving TRID hiccups? Collaboration.”
“Overall, there are a few issues with the rule itself, but the main problems seem to be from adapting to the significant workflow changes, exchanging of information and fee naming,” Hollenbeck said in the article. “In addition, various interpretations of the regulation have created a litany of approaches to completing the disclosures.”