Compliance News Alert: Nebraska Net Tangible Benefits Disclosure
Jun 10, 2020
Yesterday, the CFPB published revisions to their TRID FAQs (available at: https://www.consumerfinance.gov/policy-compliance/guidance/mortgage-resources/tila-respa-integrated-disclosures/tila-respa-integrated-disclosure-faqs/), which includes new FAQs on whether or not negative prepaid interest should be included in the Total of Payments disclosure on the CD (it should be included) and whether or not a creditor can require a consumer to sign and return the LE and CD (if a creditor requires a signed copy to be returned, the borrower must be provided with a separate copy which the borrower can retain).
We are currently reviewing these additions to the FAQs to determine any impact, and evaluating any modifications, to our document library and/or systems. Any modifications we make as a result will be announced on our website.
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The preceding is for informational purposes only and is not and may not be construed as legal advice. No third-party entity may rely upon anything contained herein when making legal and/or other determinations regarding its practices, and such third party should consult with an attorney prior to embarking upon any specific course of action.