MBA Weighs in With CFPB on Promoting Access to Credit, Questions Related to Its TRID Rule

The Mortgage Bankers Association responded to the Consumer Financial Protection Bureau in response to its request for information on Promoting Access to Credit and questions related to its TRID rule.

Overall, MBA encouraged CFPB to prioritize narrow targeted reforms that meaningfully reduce compliance burdens, improve customer understanding and expand access to credit rather than largescale, substantial changes.

MBA’s recommendations include:

• Streamline refinance transactions by eliminating the three-day rescission period;

• Adjusting tolerance thresholds for costs that are not within the creditor’s ability to control;

• Allow for a consumer, with informed written consent, to waive or modify waiting periods regardless of whether they are experiencing a bona fide personal emergency;

• Revising the definition of “application” to permit creditors to require additional information before providing the initial Loan Estimate (LE); and,

• Eliminating the TALC table from reverse mortgage disclosures.