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Volume 28 - Number 22

October 23, 2017

Industry Endorses Fixes to TRID’s Black Hole, With Some Tweaks

Leading trade groups that represent various segments of the mortgage and real estate industry generally support the changes the CFPB recently proposed to close the so-called black hole it inadvertently created when it drafted the integrated disclosure rule under the Truth in Lending Act and the Real Estate Settlement Procedures Act. “The proposal recognizes that unexpected events occur regularly and cause closings to be delayed. Those delays should not prevent closings or increase costs for other consumers who are able to close on time,” the Mortgage Bankers Association said. “Amending the integrated-disclosure requirements to address the black hole will resolve these issues, and the remaining limitations on when tolerances may be reset will afford sufficient protections for consumers.” Other industry ...

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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.