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The Consumer Financial Protection Bureau (CFPB) released a statement on April 29, 2020 providing guidance and additional clarification to certain disclosure requirements for consumers who have a financial emergency due to the Coronavirus pandemic and need to obtain funds through the quick closing of a loan.
The interpretive rule provide clarification that consumers can exercise their rights to modify or waive waiting periods required by the Truth in Lending Act and the Real Estate Settlement Procedures Act, known as TRID.
Under the new guidance, the CFPB will allow a consumer with a financial emergency to waive waiting periods if three conditions are met:
Lenders are encouraged to voluntarily inform consumers aware of their ability to use the modification and waiver provisions during the pandemic prior to the end of an applicable waiting period.
Furthermore, the bureau also indicated a “changed circumstance” can allow creditors to use revised estimates to reflect these changes in settlement charges for the purpose of determining good faith provisions.
A FAQ was published to address questions surrounding the mortgage origination rules related to the COVID-19 emergency. If you have additional questions about how this impact’s your institution’s mortgage lending operations, contact a Doeren Mayhew regulatory compliance specialist.
By Heather Feltner, Lending and Compliance Specialist
This publication is distributed for informational purposes only, with the understanding that Doeren Mayhew is not rendering legal, accounting, or other professional opinions on specific facts for matters, and, accordingly, assumes no liability whatsoever in connection with its use. Should the reader have any questions regarding any of the news articles, it is recommended that a Doeren Mayhew representative be contacted.
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