Good Tuesday morning from your nation’s capital! I’m pleased to be in attendance alongside the nearly 5,000 bank professionals at this year’s CUNA Governmental Affairs Conference (GAC). GAC is really a tremendous opportunity to network with others in the industry and share stories from the #CUdifference with this legislators and regulators.
As always, CUNA has been doing a great job of putting together a loaded agenda here in Washington, D.C. As a result, I’ll keep today’s post brief. You realize, it’s funny. I can actually hear my regular readers (the 3 of these) breathing a collective sigh of relief.
Last month the customer Financial Protection Bureau (CFPB) was kind enough to issue some clarifying guidance on complying with the Integrated Disclosure Rule (TRID) in accordance with construction loans. While many in the industry found the guidance without substance, a minimum of it’s something. Let’s take a minute to review the key points:
Construction Loans are Susceptible to TRID
While you were not required to supply the Good Faith Estimate (GFE) on construction loans because they are considered temporary financing under the Real Estate Settlement Procedures Act (RESPA), most construction loans do fall inside the scope of TRID. Consequently, both the Loan Estimate and shutting Disclosure are required to get offers for regarding the a closed-end construction loan.