WBK Industry - Federal Regulatory Developments

CFPB Releases Factsheet on TRID Title Insurance Disclosures and FAQs on Lender Credits

The CFPB recently issued a factsheet on TRID title insurance disclosures and updated its TILA-RESPA Integrated Disclosure frequently asked questions (FAQs).

The factsheet on TRID title insurance disclosures addresses, among other things: (i) disclosure requirements for simultaneous title insurance on the Loan Estimate and Closing Disclosure; (ii) differences between state disclosure and TRID disclosure requirements for simultaneous rates; (iii) simultaneous issuance if the seller agrees to pay the amount of the full owner’s title insurance premium; and (iv) negative owner’s title insurance.  The factsheet includes formulas and examples to assist lenders in disclosing the required rates.

The TILA-RESPA Integrated Disclosure FAQs were updated by adding FAQs to address: (i) seller-paid Loan Costs and Other Costs disclosure on the Closing Disclosure; (ii) Total of Payments disclosure on the Closing Disclosure; (iii) accounting of negative prepaid interest in the Total of Payments disclosure and calculation; and (iv) whether a creditor may require a consumer to sign and return the Loan Estimate or Closing Disclosure.