CLTA Sends Comments to Consumer Financial Protection Bureau on TRID
Tuesday, February 18, 2020
CLTA President Dia Demmon and CLTA Executive Vice President Craig Page signed a joint letter to the CFPB as the Bureau currently assesses the existing Truth-in-Lending RESPA Integrated Disclosure (TRID) form.
The letter focuses on the ongoing consumer confusion caused by the use of a disclosure that misrepresents the title charges that commonly occur in transactions wherein there is a simultaneous issue of an owner’s and lender’s policy. The letter points out that the current TRID form does not allow for a proper disclosure of how costs are allocated and the corresponding cost savings to the parties.
Rather than a complete overhaul of TRID, in which the title industry has invested millions in implementation, the CLTA suggests that the CFPB instead issue a survey of settlement professionals to gauge whether the buyer or seller typically pay for title costs, whether consumers experience confusion with the form, and if professionals end up providing other information to help explain the actual costs to consumers.
The CLTA also suggests that the CFPB might find that a clearer disclosure of title costs, including discounts, which do not unintentionally misrepresent a particular consumer’s costs, might be preferable to the current approach.