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In just a few short days – on Oct. 3 – the CFPB’s nearly 2,000-page Truth in Lending Act and Real Estate Settlement Procedures Act integrated disclosures rule (TRID) goes into effect.

With no time allowed for early compliance to test systems implemented as part of this complex regulatory overhaul, I continue to hear credit unions express anxiety over the impending deadline. While the bureau and NCUA have stated that examiners will consider “good faith efforts” toward “substantial compliance” with the rule, this has not eased the anxiety. What is substantial compliance? What efforts are sufficient to establish good faith? If you think these questions seem familiar, you are not alone.

TRID applies to nearly all closed-end mortgage loans regardless of a credit union’s asset size or pricing of the mortgage. All credit unions that originate closed-end mortgage loans secured by real property must comply with these new mortgage disclosure regulations. This covers not only purchases but closed-end home equity loans, refinancings, construction-only loans and loans secured by vacant land.

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