CFPB Interpretive Rule “Clarifies” TRID and
Regulation Z Waiting Periods in Light of COVID-19
The Consumer Financial Protection Bureau issued an interpretive rule on April 29 concerning the COVID-19 emergency, and the required waiting periods set forth in the TRID/RESPA Integrated Disclosure Rule and the Regulation Z rescission rule. The interpretive rule reviews a consumer’s right to modify or waive these waiting periods.
The Bureau concludes that “if a consumer determines that his or her need to obtain funds due to the COVID-19 pandemic (1) necessitates consummating the credit transaction before the end of the TRID Rule waiting periods or (2) must be met before the end of the Regulation Z Rescission Rules waiting period, then the consumer has a bona fide personal financial emergency that would permit the consumer to utilize the modification and waiver provisions.” The interpretive rule takes effect upon publication in the Federal Register.