CFPB Issues Interpretive Rule to Provide Certain Relief under TRID Rule and Regulation Z Rescission Rules Due to the COVID-19 Pandemic

In Client and Friends Memos by BMG Memorandum

In the May 4, 2020, Federal Register (85 FR 26319), the Bureau of Consumer Financial Protection (Bureau) issued an interpretive rule that (A) “if a consumer determines that his or her need to obtain funds due to the COVID-19 pandemic (1) necessitates consummating the credit transaction before the end of the TRID Rule waiting periods or (2) must be met before the end of the Regulation Z Rescission Rules waiting period, then the consumer has a bona fide personal financial emergency that would permit the consumer to utilize the modification and waiver provisions, subject to the applicable procedures set forth in the TRID Rule and Regulation Z Rescission Rules[;]” and (B) “the COVID-19 pandemic is a ‘changed circumstance’ for purposes of certain TRID Rule provisions, allowing creditors to use revised estimates reflecting changes in settlement charges for purposes of determining good faith.”

This interpretive rule is effective on May 4, 2020

 

Full Memorandum