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12 CFPB: POSSIBLE CHANGES AHEAD FOR TRID AND RESPA e Consumer Financial Protection Bureau (CFPB) has announced that is requesting public comment on an assessment it will conduct on the TRID Integrated Disclosure Rule (the Truth in Lending Act and Real Estate Settlement Procedures Act). e CFPB notes that part of the goal of the assessment is to address the TRID Rule's effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act, the specific goals of the rule, and other relevant factors. e public is invited to comment on the feasibility and effectiveness of the assessment plan, recommendations to improve the assessment plan, and recommendations for modifying, expanding, or eliminating the TRID Rule, among other questions. e TRID Rule implemented the Dodd-Frank Act's directive to combine certain mortgage disclosures that consumers receive under TILA and RESPA and requires that all creditors use standardized forms for most transactions. Creditors are also required to provide loan estimates and closing disclosures within three business days. Earlier this year, as part of the CFPB's Spring 2019 rulemaking agenda, the CFPB will be reviewing existing regulations, such as, "conducting an assessment pursuant to section 1022(d) of the Dodd-Frank Act of its regulations to consolidate various mortgage origination disclosures under the Truth in Lending Act and Real Estate Settlement Procedures Act." e CFPB finalized part of this Notice of Proposed Rulemaking when it extended for two years the current temporary threshold for collecting and reporting data about open-end lines of credit under the Home Mortgage Disclosure Act (HMDA). e rule also clarifies partial exemptions from certain HMDA requirements which Congress added in the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). Comments may be submitted through the Federal eRulemaking Portal, by email at 2019-RFI-TRID@cfpb.gov, or by mail at at Comment Intake – TRID Assessment, Consumer Financial Protection Bureau, 1700 G Street, NW, Washington, DC 20552. e comment period will open once the notice is published in the Federal Register and the deadline for submissions is January 21, 2020. FANNIE AND FREDDIE INCREASE FORECLOSURE PREVENTION ACTIONS Fannie Mae and Freddie Mac completed 8,464 foreclosure prevention actions in August, bringing the total to 4,372,944 since the start of the conservatorships in September 2008, according to the latest FHFA Foreclosure Prevention, Refinance and FPM Report. ere were 5,721 permanent loan modifications in August, bringing the total to 2,368,691 since the conservatorship began in September 2008. Additionally, the GSE's serious delinquency rate remained unchanged at 0.65% at the end of August from July. Total refinance volume increased in August 2019 as mortgage rates fell in previous months. Mortgage rates decreased in August: the average interest rate on 30‐year fixed-rate mortgage fell to 3.62% from 3.77% in July. Freddie Mac recently announced that its Single-Family Credit Risk Transfer (CRT) programs had surpassed the $50 billion mark in transferring credit risk to private investors and (re)insurers. From program inception to date, the company has transferred a portion of the credit risk on more than $1.3 trillion single-family mortgages based on unpaid principal balance (UPB) at issuance. Per FHFA guidelines, Freddie Mac now transfers the credit risk on more than 90% of the UPB on CRT-eligible, newly-acquired single-family mortgages. "I am proud of our accomplishments and the positive impact we are making on the U.S. housing finance industry," said Mike Reynolds, VP, Single-Family Credit Risk Transfer. "Freddie Mac will continue to lead the industry with innovation in the CRT space and set the standard for credit risk management." e goal of Freddie Mac's Single-Family CRT programs is to transfer credit risk away from U.S. taxpayers to global private capital via securities and (re)insurance policies. Earlier this year, Freddie Mac reported a slight increase in comprehensive income in Q2 2019 from the previous quarter, up to $1.8 billion. "Freddie Mac's second quarter continued our growing track record of strong returns, solid risk management, and an unwavering commitment to our mission," said Freddie Mac CEO David Brickman. "Once again, we made home possible for hundreds of thousands of families across the country."

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