Pub. 8 2018 Issue 1

8 ISSUE 2. 2017 W HILE WE WERE EAGERLY AWAITING A FINAL RULE FROM THE CFPB ON THE SO-CALLED “BLACK HOLE” TOLERANCE ISSUE, A NEW BILL WAS SWIFTLY PASSED BY THE HOUSE OF REPRESENTATIVES LAST MONTH: THE TRID (TILA-RESPA INTEGRATED DISCLOSURE) IMPROVEMENT ACT OF 2017. On October 5, 2017, Congressman French Hill introduced H.R. 3978, which eventually had four other bills tacked onto it, making it a five-in-one set of changes for the financial services industry. One of these bills, the TRID Improvement Act, specifically amends and clarifies how title insurance premiums and discounts are disclosed on the Loan Estimate and Closing Disclosure. On February 14th, the House of Representative passed the bipartisan bill by a healthy 271 to 145 vote. Now you may be asking yourself, “What exactly is the problem with how title insurance is disclosed?” Well, to put it simply, it isn’t disclosed the way it is actually charged, and some argue that this is counter to the general spirit and intent of the TRID rule. As Is the ‘TRID Improvement Act’ an Improvement? By Victoria E. Stephen, Associate General Counsel, CRCM