May 1, 2020
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.

Click here to see the CFPB interpretive rule.
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Please continue to check out our dedicated webpage for COVID-19 information and guidance, on a regular basis. We will be updating the material as we learn of new developments.