- Business Rules
What about the fees charged by Title Companies? Those are not known at the point of sale or even in the middle of the process necessarily.Disclosures may be estimated when the exact information is unknown at the time disclosures are made. Information is unknown if it is not reasonably available to the creditor at the time the disclosures are made. The "reasonably available" standard requires that the creditor, acting in good faith, exercises due diligence in obtaining information.
Citation(s): Commentary ¶17(c)(2)(i) and Commentary ¶37–1
CFPB announcement regarding the delay of TRID
The full statement from CFPB Director Richard Cordray can be viewed here