What do you get when you attempt to abbreviate "Truth-in-Lending Act," "Real Estate Settlement Procedures Act" and "Integrated Disclosures?" Well, if you are the CFPB, you get TRID, an acronym for two consolidated consumer real estate loan disclosure forms that represent many years and countless hours of research and development. The TRID forms consolidate two separate loan disclosures that had been required for decades by two different federal consumer protection laws and regulations recombining them into two different forms; one to be provided at the time of application and the other, at the time a closed-end consumer real estate loan is closed. For those wanting to dig a little deeper, let's break this down.

On Aug. 11, 2017, the CFPB published a Final Rule in the Federal Register to formalize guidance and to provide greater clarity and certainty regarding specific mortgage disclosure provisions implemented by Regulation Z (2017 TILA-RESPA Rule). Although the Final Rule became effective on Oct. 10, 2017, 60 days after publication, compliance is not mandatory until Oct. 1, 2018. Confused? Aren't the TRID disclosures already required? Let's back up and review.

For decades credit unions provided consumer residential loan applicants with two unique disclosure forms required by two federal laws: The federal Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA). The two forms were typically given to consumers within three days after they applied for closed-end mortgage loans, and updated versions of one (and often both) of these forms were provided just prior to, or at the time of loan closing. The regulations requiring the use of each form had been prescribed and developed by two different federal regulatory agencies. The Federal Reserve Board was responsible for Regulation Z, which implemented the TILA, and the Department of Housing and Urban Development was charged with generating the settlement cost disclosures (the Good Faith Estimate and the HUD-1/HUD-1A Settlement Statement) required by RESPA. The problem was that the content and timing requirements of the two regulations were not completely in sync. The terminology used by the two agencies was not always consistent, and there was a fair amount of overlap between the two forms. As a result, loan settlement agents had a hard time explaining the forms to consumers who were often left scratching their heads at the closing table.