The CFPB notes that it was contacted by stakeholders asking whether the COVID-19 national emergency constitutes an extraordinary event that rises to the level of a changed circumstance that would permit a creditor to increase a settlement charge, such as an appraisal fee. For purposes of the TRID rule, a changed circumstance includes, among other situations, an “extraordinary event beyond the control of any interested party,” and the Commentary to the TRID rule indicates that a “war or natural disaster” is an example of such an extraordinary event. One situation in which an increase is permitted is if the increase is based on a changed circumstance that affects one or more settlement charges. The TRID rule limits the ability of a creditor to increase various fees, such as appraisal fees, above the amount disclosed in the initial Loan Estimate. The CFPB also issued a compliance aid in the form of a FAQ regarding the ability of a mortgage loan applicant to waive the timing requirement under Equal Credit Opportunity Act (ECOA) and Regulation B provisions that require creditors to provide the applicant with a copy of any written appraisal or other valuation developed in connection with the application (ECOA Valuations Rule).Ĭhanged Circumstances. The interpretive rule will become effective upon publication in the Federal Register. On April 29, 2020, the Consumer Financial Protection Bureau (CFPB) announced an interpretive rule addressing the waiting periods under the Regulation Z right to rescind provisions and the TRID rule in view of COVID-19, and also whether increases in fees based on COVID-19 constitute a changed circumstance under the TRID rule.

Loan estimate 3 day rule