Washington Report

Advocacy Updates from Washington D.C.

NAR Comments on CFPB Black Hole Fix

On October 10, 2017, NAR sent a letter to the Consumer Financial Protection Bureau (CFPB) commenting on its proposed rule amending the Know Before You Owe (KBYO) regulation, also known as TRID, which addresses the so-called "black hole" issue. This proposed rule is examining how creditors may use a Closing Disclosure (CD) to reflect changes in costs imposed on consumers. In the comment letter, NAR advocated for adoption of the proposed rule, which allows for lenders’ flexibility in being able to reissue a CD to determine if a closing cost was disclosed in good faith, regardless of when the CD is provided relative to consummation. NAR explained the advantages to having information early on in the closing process, which helps facilitate improved communication and an overall more transparent process for the consumer.

View the proposed rule

View NAR’s comment letter

View the CFPB Press Release on the proposed rule