On May 1, 2019, the CFPB issued a Fact Sheet discussing TRID applicability for assumptions. This six-page document answers the question of whether Loan Estimates (LEs) and Closing Disclosures (CDs) are required for assumptions and contains two main parts: 1) a flowchart and 2) a narrative discussion. The flowchart is a quick reference that highlights the major questions to be answered when determining if a Loan Estimate and Closing Disclosure are required for the assumption transactions described above. The narrative discussion provides general information that may be useful when determining if a Loan Estimate and Closing Disclosure are required, including information related to each of the major questions set forth in the flowchart.
As you would expect, this topic will be included in our 2Q 2019 Quarterly Compliance Update, planned to be released in July/August.
The full CFPB factsheet can be found here.