In today’s Federal Register (81 FR 54318, click here) the CFPB published the proposed amendments to the integrated mortgage disclosure rules that became effective on October 3, 2015 (TRID Rule), which would: • Memorialize past informal guidance. Memorialize certain past informal guidance issued through webinar, compliance guide, or otherwise. • Create tolerances for the total of payments. Establish express tolerances for the total of payments to parallel the existing provisions regarding the tolerances for accuracy in calculating the finance charge and disclosures affected by the finance charge. • Adjust a partial exemption that affects housing finance agencies and nonprofits. Propose two amendments to expand the reach of the partial exemption for certain non-interest bearing subordinate lien transactions that provide down payment and other homeowner assistance (housing assistance loans). • Provide a uniform rule regarding application of the integrated mortgage disclosure requirements to cooperative units. Require provision of the integrated disclosures in transactions involving cooperative units, whether or not cooperatives are classified under State law as real property.

Complete Memorandum