On July 9, the CFPB issued a request for information (RFI) seeking comments on potential regulatory changes to reduce mortgage origination burdens and promote access to mortgage credit. The RFI was issued pursuant to Executive Order 14393, “Promoting Access to Mortgage Credit,” signed on March 13 (previously covered by InfoBytes here). The executive order directed the CFPB to consider, among other things, amendments to TILA-RESPA integrated disclosure (TRID) requirements, replacing TRID timing rules with a materiality-based standard, and exempting rate-and-term and cash-out refinancing from rescission rights. The RFI poses 22 questions across four areas: (i) TRID timing requirements; (ii) other TRID requirements; (iii) tailored requirements for small banks and credit unions; and (iv) reverse mortgages.
The RFI builds on prior public input, including a 2019 RFI (covered by InfoBytes here) and the resulting 2020 TRID Rule Assessment Report (covered here), which summarized industry comments. The RFI addresses several recurring industry concerns, notably the difficulty creditors encounter in providing accurate estimates for fees such as transfer taxes and third-party appraisals within the three-business-day timeframe. Additionally, it observes that the process of tracking changes and issuing updated disclosures is considered burdensome, and that overlapping waiting periods for refinance transactions can be redundant. The RFI also asks whether materiality-based standards could replace or supplement existing timing rules, with the aim of preserving consumer clarity and reducing closing delays. It also seeks input on how any proposed changes might affect the secondary market, including potential impacts on pricing, liquidity, and demand for mortgage-backed securities. Comments on the RFI are due August 10.
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