COVID-19 TRID and Rescission Interpretive Rule Summary

The Bureau of Consumer Financial Protection (“CFPB”) issued this interpretive rule clarifying the application of certain provisions in the TILA-RESPA Integrated Disclosure (TRID) Rule and Regulation Z’s right of rescission rules (Rescission Rules) in light of the COVID-19 pandemic. As an interpretive rule it doesn’t impose new or change existing substantive requirements; rather, it interprets the law set out in the TRID and Rescission Rules. The CFPB concluded that if a consumer determines that their need to obtain funds due to the COVID-19 pandemic necessitates consummating the transaction before the end of the TRID Rule waiting periods or must be met before the end of the Rescission Rules waiting period, then the consumer has a bona fide personal financial emergency. The CFBP also concluded that the COVID-19 pandemic is a “changed circumstance” for purposes of certain TRID Rule provisions.

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