TRID Compliance Issues Disclosed on New Nonprime MBS
September 6, 2016
The new nonprime mortgage-backed securities deals from Angel Oak Capital Advisors and Deephaven Mortgage contain a number of mortgages reflecting a range of issues in terms of complying with the CFPB’s TILA/RESPA Integrated Disclosure rule (TRID), a review of the offering documents revealed. Part of the compliance issues stem from the ongoing uncertainty about cures for minor errors. While the CFPB issued a proposed rule in July attempting to clarify some of these TRID uncertainties, and the Structured Finance Industry Group has worked with industry participants on a set of guidelines, it is still not clear whether some TRID errors can be cured. The $132.65 million nonprime MBS from Angel Oak included 251 mortgages subject to TRID, representing 59.4 percent ...