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Volume 28 - Number 22

October 23, 2017

CFPB Must Provide TRID Cures, Resolve Liability Issues: Chase

JPMorgan Chase exhorted the CFPB to address some fundamental flaws in the integrated disclosure rule under the Truth in Lending Act and the Real Estate Settlement Procedures Act – namely, an insufficient capability for lenders to “cure” the inevitable errors that occur and the significant legal liability lenders and assignees face. As the lender spelled out in its public comments to the CFPB regarding its proposed solution to the TRID “black hole” (see following story), these are two significant hurdles that are keeping private capital from returning in full force to the mortgage market. Chase urged the bureau to address a number of unresolved concerns the industry has brought up since the rule was adopted, in order to foster stability and ...

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Who "owns" the mortgage customer that’s brought to a wholesale lender through a loan broker?

The broker. It’s his/her client.


The wholesale/table funder. They’re taking the financial risk.


The broker, but only for the first year. After that, the borrower is fair game.


Hard to answer. It’s a complicated issue.