Mortgage lenders have had a little more than three months to get used to the CFPB’s integrated disclosure rule, but many are still squirming with uncertainty about civil liability and enforcement, particularly when it comes to errors in the Loan Estimate and the Closing Disclosure. Much of the problem stems from ambiguity in the wording of the rule itself. “Although TRID implements portions of the Truth in Lending Act and the Real Estate Settlement Procedures Act, the text of the regulation does not state which statutory liability applies to the various parts of the rule or forms,” K&L Gates attorneys Holly Spencer Bunting and Charles Weinstein said in a recent review. Instead, civil liability under TRID is a matter that ...