TRID (TILA-RESPA Integrated Disclosure) (2024)


What is the fundamental issue?

For a number of years, the Consumer Financial Protection Bureau (CFPB) has been working to harmonize the Real Estate Settlement Procedures Act (RESPA) and Truth in Lending Act (TILA) disclosures and regulations. The final Know Before You Owe (KBYO or TRID) rule has helped clarify real estate sales transactions, but initially faced many questions, complications, and costs related to the implementation that began on October 3, 2015.

I am a real estate professional. What does this mean for my business?

The new KBYO integrated disclosures replace the long-standing Good Faith Estimate (GFE) and HUD-1 settlement statement. Like any new process, there has been a learning curve with unanticipated hurdles. This uncertainty has generated a degree of risk aversion on the part of lenders that has led to a more tightly lender-controlled closing process. Of concern is a requirement that the Closing Disclosure (CD) be issued three days before closing, what adjustments can be made to the CD after it has been issued, and the potential delays that could result. Additionally, agents have reported reluctance by lenders and title companies to share the CD out of fear of liability for disclosing clients' nonpublic personal information. The CFPB has been working to address these outstanding concerns through subsequent rulemakings since 2015.

NAR Policy:

NAR supports a RESPA/TILA harmonization that adds transparency, simplifies disclosures, and reduces burdens to settlement service providers, including real estate professionals. RESPA and TILA are confusing statutes with sometimes conflicting disclosures and procedures. A single reformed set of rules and initial disclosures could benefit settlement service providers and consumers, ultimately improving the settlement process.

Legislative/Regulatory Status/Outlook

The final Know Before You Owe (KBYO) mortgage disclosure rule was issued November 20, 2013, and went into effect on October 3, 2015.

In the final rule, the CFPB largely addressed NAR’s major concerns regarding the proposed 3-day waiting period to close transactions and dropped many provisions including the “all in” APR that would have been problematic. However, concerns of possible closing delays and how the mortgage transaction interacts with the real estate transaction remained. For instance, real estate agent access to the CD continued to be problematic as lenders argued that the privacy requirements of the Gramm-Leach-Bliley Act (GLBA) or Regulation P prohibited them from releasing the CD to the real estate agent. However, an exception to the law and regulation already allows lenders to distribute the CD to third parties, including real estate professionals, which was eventually clarified by the Bureau thanks to advocacy efforts by NAR

Upon the proposal stages of the rule, NAR strongly advocated for a period of restrained enforcement and liability for the rule. It was through NAR member efforts during the 2015 REALTOR® Legislative Meetings that almost 300 U.S. Senators and Representatives signed a letter to CFPB Director Richard Cordray asking him to grant a period of restrained enforcement, which the CFPB subsequently granted. In June 2016, NAR sent a letter to the CFPB requesting guidance on several concerning issues still causing problems for consumers and industry, including seeking: clarity on lenders’ ability to share the CD with third parties; insight on revising the CD to reflect changes in circ*mstances (the so-called "black hole"); and extension of post-consummation timelines to correct minor errors to reduce impact on the secondary market.

On July 29, 2016, the CFPB issued a proposed rule addressing some of these concerns. As advocated for by NAR, the CFPB included explicit language acknowledging that sharing the CD with real estate professionals is permitted under existing privacy laws (GLBA and Regulation P). Thus, the KBYO rule did not impact the existing privacy law exception that allowed for CD sharing. Therefore, lenders that continue to show reluctance in sharing the CD out of fear of liability for disclosing clients’ nonpublic personal information remains unwarranted.

On October 18, 2016, NAR sent a letter to the CFPB commenting on the latest proposed rule urging the CFPB to: (1) emphasize that lenders and title agents should share the CD with real estate agents, in accordance with existing privacy law and regulation; (2) ensure lenders are able to revise the CD to reflect valid changes in circ*mstances; (3) extend post-consummation timelines to correct minor KBYO errors; and (4) implement additional modifications to decrease consumer and industry uncertainty.

On July 7, 2017, the BCFP released the final rule amending the “Know Before You Owe” (KBYO or TRID) mortgage disclosure rule and clarified the ability to share the CD with third parties - a victory for real estate professionals nationwide. The final rule was became effective on October 10, 2017, with mandatory compliance required by October 1, 2018.

At the same time as the final rule was released, the CFPB issued a proposed rule looking at the outstanding "black hole" issue related to creditors' ability to use a CD to reflect changes in costs imposed on consumers. On October 10, 2017, NAR sent a letter to the CFPB commenting on the proposed rule, advocating for lenders’ flexibility in being able to reissue a CD to determine if a closing cost was disclosed in good faith, regardless of when the CD is provided relative to consummation. NAR explained the advantages to having information early on in the closing process, which helps facilitate improved communication and an overall more transparent process for the consumer. A final rule was issued on April 26, 2018, and became effective June 1, 2018. Since that time, the CFPB has updated its TILA-RESPA Integrated Disclosure Frequently Asked Questions (FAQs), which provides guidance to help ensure compliance with TRID-RESPA Integrate Disclosure Rule.

In the fall of 2019, the CFPB began its five-year assessment of the TRID rule, as mandated by law, to examine the implementation costs and regulatory benefits since the rule was enacted. A Request for Information (RFI) was issued, which NAR provided comments following extensive outreach to members on the effect of the rule on consumers and their businesses. For example, there continues to be frustration with the mandatory three business-day waiting period that occurs when there are certain changes made after an initial disclosure has been provided. NAR advocated for more flexibility for consumer waivers to protect against unnecessary delays and frustrations with this waiting period. The Bureau issued the five-year lookback assessment on October 1, 2020, which reported how the TRID rule improved consumers’ experience to locate key mortgage information and compare mortgage offers. The CFPB also published a Data Point that examined changes consumers face regarding terms and costs of a mortgage loan throughout the transaction. There, the CFPB reported that almost 90 percent of mortgage loans involved at least one revision, 62 percent received at least one revised LE, and 49 percent received at least one corrected CD. The Bureau will use this information in determining future changes to the rule, which NAR will continue to provide feedback.

NAR Committee:

Business Issues Policy Committee

Current Legislation/Regulation

CFPB Final Rule

Public Law 111-203 (HR 4173, The Dodd Frank Wall Street Reform and Consumer Protection Act)


Congressional testimonies
Letters to federal agencies
NAR Federal Issues Tracker

Legislative Contact(s):

Christie DeSanctis

Vijay Yadlapati

Regulatory Contact(s):

Christie DeSanctis

Nia Duggins


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Before you search elsewhere, take advantage of the research we've already done for you. Formerly known as Field Guides, References tabs contain links to external articles, titles from the NAR Library eBooks collection, websites, statistics, and other material to provide a comprehensive overview of perspectives on each topic. EBSCO articles (E) are available only to NAR members and require apassword.

TRID Essentials

TILA-RESPA Integrated Disclosure FAQs (U.S. Consumer Financial Protection Bureau, May 14, 2021)

The Consumer Financial Protection Bureau’s “list of commonly asked questions and answers on particular topics to assist in understanding and complying with the TRID rules.”

TRID Closing Disclosures Guide (National Association of REALTORS®, Jun. 2020)

Guidance on how TRID regulations apply to common issues regarding combined and separate Closing Disclosures and an agent’s ability to obtain settlement information for both parties to the transaction.

Know Before You Owe: The Real Estate Professional’s Guide (U.S. Consumer Financial Protection Bureau)

Information and printable resources for real estate professionals to help their clients understand CFPB’s “Know Before You Owe” mortgage initiative.

TILA-RESPA Integrated Disclosures (TRID) (U.S. Consumer Financial Protection Bureau)

CFPB’s landing page for “resources to help industry participants understand, implement, and comply with the TILA-RESPA Integrated Disclosure (TRID) rules.”

TRID Background & Updates

Truth in Lending (Regulation Z) Annual Threshold Adjustments (Credit Cards, HOEPA, and Qualified Mortgages) (Federal Register, Dec. 23, 2022)

“The Consumer Financial Protection Bureau (Bureau) is issuing this final rule amending the regulation text and official interpretations for Regulation Z, which implements the Truth in Lending Act (TILA). The Bureau calculates the dollar amounts for several provisions in Regulation Z annually; this final rule revises, as applicable, the dollar amounts for provisions implementing TILA and amendments to TILA, including under the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The Bureau is adjusting these amounts, where appropriate, based on the annual percentage change reflected in the Consumer Price Index (CPI) in effect on June 1, 2022.”

A Refresher on Triggering Events Impacting the Revised Loan Estimate (Wolters Kluwer, Nov. 2021)

“One way to limit tolerance violations is to consider whether the increased fee triggers a revised loan estimate. The TRID rule sets out six events that allow using a revised loan estimate for purposes of re-setting fees and performing the good-faith analysis. Those six events include:

  • Changed circ*mstances that cause an increase to settlement charges
  • Changed circ*mstances that affect the consumer’s eligibility for the loan or affect the value of the property securing the loan
  • Consumer-requested changes
  • Interest rate locks
  • Expiration of the original loan estimate
  • Construction loan settlement delays”

CFPB Issues Interpretive Rule on Juneteenth-Related Mortgage Closing Delays (ABA Banking Journal, Aug. 5, 2021)

“Today’s guidance addresses Regulation Z timing requirements related to rescission of closed-end mortgages and the TILA-RESPA integrated disclosures. It clarifies that “if the relevant closed-end rescission or TRID time period began on or before June 17, 2021, then June 19, 2021 was considered a business day, but nothing prohibits creditors from providing longer time periods. Therefore, it would also be compliant for creditors to have considered June 19, 2021 a Federal holiday for purposes of these provisions.””

CFPB Issues TRID Rule FAQs on BUILD Act Partial Exemption (Ballard Spahr, May 17, 2021)

The recent update to CFPB’s TRID FAQ document addresses “a partial exemption added by the Building Up Independent Lives and Dreams Act (BUILD Act) that became law in January 2021. Before the adoption of the BUILD Act, Regulation Z under TILA already included a partial exemption from the Loan Estimate and Closing Disclosure requirements of the TRID rule for subordinate housing assistance loans that met certain conditions. The BUILD Act added a partial statutory exemption from such requirements for similar transactions”

2019 CFPB Closing Process Rules Survey (National Association of REALTORS®, Jan. 24, 2020)

NAR’s survey of member experiences with TRID or “Know Before You Owe” disclosures finds that “overall, respondents have not observed any change in their or consumers’ general experiences or behavior. However, thirty percent reported that their ability to close a transaction on time has decreased slightly due to TRID.”

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TRID (TILA-RESPA Integrated Disclosure) (2024)


What is the TILA-RESPA integrated disclosures Trid rule? ›

The rule is also known as the TILA-RESPA Rule or TRID. It created new Loan Estimate and Closing Disclosure forms that consumers receive when applying for and closing on a mortgage loan. The Loan Estimate replaced the RESPA Good Faith Estimate (GFE) and the early Truth in Lending disclosure.

What is the difference between TILA and Trid? ›

TRID is an acronym that stands for TILA-RESPA Integrated Disclosures. It combines two federal laws, the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA). Both protect borrowers by requiring lenders to disclose key information about mortgage loans within mandatory timelines.

Which action is not a requirement under the TILA-RESPA integrated disclosure rule (TRID)? ›

The answer is: C. settlement involving a cash purchase of a home to be used as a primary residence. A Closing Disclosure sets forth the final terms and conditions of a residential mortgage loan. If no loan is required in the purchase of residential real property, the Closing Disclosure is not necessary.

What are the two disclosures required by Trid? ›

The TRID rule requires lenders to provide two disclosure documents to lenders: a loan estimate and a closing disclosure. Because each document must be timed to give the borrower three days to look it over, it's sometimes referred to as the “three-day rule.”

What are the 4 main disclosures required under TILA? ›

TILA disclosures include the number of payments, the monthly payment, late fees, whether a borrower can prepay the loan without penalty and other important terms. TILA disclosures is often provided as part of the loan contract, so the borrower may be given the entire contract for review when the TILA is requested.

What is the TILA disclosure requirement? ›

The federal Truth-in-Lending Act (TILA) requires lenders and dealers to provide you with certain disclosures – before you sign your contract – that explain your auto loan's costs and terms.

How are RESPA and TILA different? ›

Two different federal statutes were relied upon: The Truth in Lending Act (TILA) which required the Truth in Lending disclosure, and the Real Estate Settlement Procedures Act of 1974 (RESPA) which required the HUD-1 settlement statement.

What is the TILA in simple terms? ›

The Truth in Lending Act (TILA) protects you against inaccurate and unfair credit billing and credit card practices. It requires lenders to provide you with loan cost information so that you can comparison shop for certain types of loans.

What does the Trid rule not apply to? ›

The TRID Rule applies to most types of mortgage loans. Mortgage loans to which the TRID Rule does not apply include HELOCs, reverse mortgage loans, or mortgage loans secured by a mobile home or dwelling that is not attached to real property.

What is the 3 day rule for Trid? ›

The three-day period is meas- ured by days, not hours. Thus, disclosures must be delivered three days before closing, and not 72 hours prior to closing.

What is exempt from TILA disclosure requirements? ›

The Truth in Lending Act (and Regulation Z) explains which transactions are exempt from the disclosure requirements, including: loans primarily for business, commercial, agricultural, or organizational purposes. federal student loans.

What are the six pieces of RESPA? ›

An application is defined as the submission of six pieces of information: (1) the consumer's name, (2) the consumer's income, (3) the consumer's Social Security number to obtain a credit report (or other unique identifier if the consumer has no Social Security number), (4) the property address, (5) an estimate of the ...

Which disclosure is required by RESPA? ›

Servicing Disclosure Statement

RESPA requires the lender or mortgage broker to tell you in writing, when you apply for a loan or within the next three business days, whether it expects that someone else will be servicing your loan (collecting your payments).

What are RESPA disclosure requirements? ›

The Act requires lenders, mortgage brokers, or servicers of home loans to provide borrowers with pertinent and timely disclosures regarding the nature and costs of the real estate settlement process. The Act also prohibits specific practices, such as kickbacks, and places limitations upon the use of escrow accounts.

Why were the TILA RESPA integrated disclosures created? ›

The TRID (TILA-RESPA Integrated Disclosure) rule took effect in 2015 for the purpose of harmonizing the Real Estate Settlement Procedures Act (RESPA) and Truth in Lending Act (TILA) disclosures and regulations.

What does the Trid rule only apply to? ›

TRID applies to most mortgages, construction-only loans, loans secured by vacant land or by 25 or more acres, home refinancing, closed-end home equity loans, and tax or estate planning for specified trusts.

Which statement best represents the provisions of the TILA-RESPA integrated disclosure trid rule? ›

Which statement BEST represents the provisions of the TILA-RESPA Integrated Disclosure (TRID) Rule? The Closing Disclosure must be provided to the buyer three days before closing.

What is the TILA QM rule? ›

The Ability-to-Repay/Qualified Mortgage Rule (ATR/QM Rule) requires a creditor to make a reasonable, good faith determination of a consumer's ability to repay a residential mortgage loan according to its terms.

What are two of the loans subject to the Trid rules? ›

TRID rules apply to MOST consumer credit transactions secured by real property. These include mortgages, refinancing, construction-only loans closed-end home-equity loans, and loans secured by vacant land or by 25 or more acres.

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