The mortgage industry submitted a flurry of detailed responses yesterday as the comment period closed on a major federal review of disclosure rules that govern nearly every home loan in America. The Consumer Financial Protection Bureau’s 30-day request for information, which closed Monday, had received 303 responses as of 5:30 p.m. EDT—feedback that could reshape how lenders provide loan estimates and closing disclosures to homebuyers.
The CFPB is requesting information on industry and consumer burdens related to the integrated mortgage disclosures under the Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) (TILA-RESPA integrated disclosures or TRID), the right of rescission, and reverse mortgage disclosures. The review stems from a March 2026 executive order directing federal agencies to reduce regulatory burdens on mortgage lenders, particularly community banks and smaller institutions.
For homebuyers, the outcome could mean faster closings, fewer last-minute delays, and potentially lower costs—but also changes to the consumer protections built into the disclosure process over the past decade.
The review
What TRID is and why it matters to homebuyers
The “Know Before You Owe” rule sets the timeline and accuracy standards for your loan paperwork
Short for TILA-RESPA Integrated Disclosure, TRID is also known as the “Know Before You Owe” rule. It combines mortgage disclosures under the Truth in Lending Act and the Real Estate Settlement Procedures Act. In November 2013, the Bureau issued a final Rule, Integrated Mortgage Disclosures Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z) Rule (the “TRID Rule”), which took effect on Oct. 3, 2015.
The TRID rules, which became effective in 2015, integrated disclosures required under the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA) into two primary forms: the Loan Estimate and the Closing Disclosure. When you apply for a mortgage, your lender must provide a Loan Estimate within three business days. Then, you must receive a Closing Disclosure at least three business days before your closing date—a waiting period designed to give you time to review final terms and catch any surprises.
The rule also sets strict “tolerance” limits on how much certain fees can increase between the initial estimate and closing. Under the current rule, certain charges, including charges paid to creditors or mortgage brokers and transfer taxes, are subject to zero tolerance, while recording fees and certain unaffiliated third-party charges are subject to an aggregate 10 percent tolerance when the consumer is permitted to shop but selects a provider identified by the creditor. If a lender exceeds these limits without a valid reason, they must refund the difference to you.
The RFI by the numbers
The RFI has 22 questions, divided into several topic areas: Timing Requirements—TRID Rule and Right of Rescission, nine questions; Other TRID Requirements, seven questions; Tailored Requirements for Small Banks and Credit Unions; two questions; Reverse Mortgages, four questions. Comments must be received on or before August 10, 2026. The official request for information was published on July 9, 2026, giving stakeholders exactly 30 days to respond. You can view the full text of the RFI and all submitted comments at the federal regulations portal.
Industry concerns
What lenders and banks are asking the CFPB to change
Timing rules, fee tolerances, and compliance burdens dominate the feedback
While some respondents provided feedback on all 22 of the CFPB’s questions, many focused on the TRID rule. The responses reveal widespread frustration with aspects of the regulation that lenders say add cost and delay without meaningfully protecting consumers.
One of the most common complaints centers on the “zero tolerance” category for certain fees. Commenters stated that transfer taxes and third-party appraisal fees are particularly difficult for creditors to estimate within three business days of application and that the CFPB should not include these fees in the zero tolerance category. Transfer taxes vary by jurisdiction and often can’t be pinned down until late in the transaction, yet lenders face penalties if the disclosed amount is off by even a dollar.
The timing requirements also drew heavy criticism. The CFPB notes that, in response to its prior TRID assessment RFI, several commenters stated that tracking changed circumstances and issuing revised estimates within three business days is unduly burdensome. Each time a fee changes or a circumstance shifts, lenders must issue a revised disclosure within three business days—a cycle that can repeat multiple times in a single transaction.
The Independent Community Bankers of America’s letter on TRID called for such things as a clear materiality standard, streamlined re-disclosure requirements and creating what it termed “a reasonable tolerance” for fees disclosed on the Loan Estimate to account for routine changes during the loan process. The trade group representing smaller banks has been particularly vocal about the burden these rules place on institutions with limited compliance staff.
A materiality-based alternative?
One of the most significant questions the CFPB posed asks whether timing rules could be replaced with a “materiality” standard. Are there any materiality-based standards that could replace or supplement timing rules, recognizing TILA’s timing requirements for delivery of disclosures after application and before consummation—including issuance of a revised disclosure upon a change in APR above the prescribed tolerance? Under this approach, lenders might only need to redisclose when changes are significant enough to affect a borrower’s decision, rather than for every minor fee adjustment. Rather than relying exclusively on fixed timing deadlines, the CFPB is asking whether certain disclosure obligations should instead depend upon the significance of the underlying change. Such an approach could fundamentally change how lenders evaluate disclosure obligations, particularly when minor changes occur late in the origination process.
The bigger picture
Where this review came from and what happens next
An executive order set the process in motion; actual rule changes could take years
The RFI was issued pursuant to Executive Order 14393, “Promoting Access to Mortgage Credit,” signed on March 13, 2026. The executive order directed the CFPB to consider, among other things, amendments to TILA-RESPA integrated disclosure (TRID) requirements, replacing TRID timing rules with a materiality-based standard, and exempting rate-and-term and cash-out refinancing from rescission rights.
The RFI is based on the March 2026 Executive Order (EO) 14393 entitled “Promoting Access to Mortgage Credit”. The EO focuses on promoting mortgage originations by community banks and banks with less than $100 million in assets. The order reflects longstanding industry arguments that post-2008 mortgage regulations went too far, making it harder for smaller lenders to compete and for some borrowers to get loans.
But don’t expect quick changes. Industry professionals should not hope for quick changes, since the CFPB is likely to conduct extensive consumer testing as it has in the past. “Regardless of the potentially lengthy rulemaking timelines and a potential for a change in administration, comments could definitely support the CFPB’s future rulemaking in these areas,” he said, noted Richard Horn, a former CFPB senior counsel who led the original TRID rule development.
The RFI is only the beginning of the process. Following the comment period, the CFPB may decide to take no action, issue additional guidance, propose targeted amendments, or pursue broader rulemaking initiatives. If the bureau does propose changes, there will be another comment period, followed by consumer testing of any new disclosure forms, and then a final rule—a process that typically takes 18 months to several years.
The CFPB has been here before. The assessment found that the TRID Rule made progress towards several of its goals. The evidence available for the assessment indicates that the TRID Rule improved consumers’ ability to locate key information, compare terms and costs between initial disclosures and final disclosures, and compare terms and costs across mortgage offers, according to a 2020 bureau assessment. But the assessment also found that the Rule resulted in sizeable implementation costs for companies.
What this means for you as a buyer
If you’re shopping for a mortgage right now, nothing changes. The current TRID rules remain in effect, and your lender must follow them. You’ll still receive your Loan Estimate within three business days of applying and your Closing Disclosure at least three days before closing. If the CFPB eventually proposes changes, they would go through a lengthy process including public comment and likely wouldn’t take effect for at least a year or two. Any changes aimed at reducing lender burden could, in theory, lead to faster closings or slightly lower costs—but consumer advocates will push to preserve protections that prevent last-minute surprises. For now, use those three-day windows to carefully review your loan terms and compare your final costs to your initial estimate.
Quick answers
TRID rule review: common questions
What is TRID and how does it affect my mortgage?
TRID stands for TILA-RESPA Integrated Disclosure, also called the “Know Before You Owe” rule. It requires your lender to give you a standardized Loan Estimate within three business days of your application and a Closing Disclosure at least three business days before closing. These forms show all your loan costs in a clear format and set limits on how much certain fees can increase. The rule has been in effect since October 2015 and applies to nearly all mortgages for home purchases and refinances.
Why is the CFPB reviewing the TRID rule now?
A March 2026 executive order directed the CFPB to review mortgage regulations that may burden lenders, particularly smaller banks and credit unions. The bureau issued a request for information in July asking for feedback on whether TRID’s timing requirements, fee tolerances, and other provisions should be changed to reduce costs and speed up loan closings while still protecting consumers. The comment period closed August 10, 2026, with over 300 responses submitted.
What changes are lenders asking for?
Industry groups are asking the CFPB to relax “zero tolerance” rules for fees like transfer taxes that are hard to estimate early in the process, replace strict three-day redisclosure deadlines with a “materiality” standard that focuses on significant changes, provide clearer guidance on when revised disclosures are required, and consider exemptions or simplified requirements for small banks and credit unions. Some groups also want to eliminate or reduce the three-day rescission period for refinances.
Will these changes make it easier or harder for me to buy a house?
It depends on what changes, if any, the CFPB ultimately makes. Reducing lender compliance costs could theoretically lead to slightly lower fees or faster closings. But weakening disclosure timing or accuracy requirements could also mean less time to review your final loan terms or more surprises at closing. Consumer advocates will likely push back against changes that reduce buyer protections. Any rule changes are years away and would go through extensive public review and testing.
When will I know if the rules are changing?
Not for a long time. The CFPB will review the 303 comments it received, then decide whether to propose any changes. If it does, there will be another public comment period, consumer testing of new forms, and a final rule—a process that typically takes 18 months to several years. The earliest any changes would take effect is likely late 2027 or 2028. The current TRID rules remain in place for all loans closing now and in the near future.
Where can I read the actual comments submitted to the CFPB?
All comments are public and posted at Regulations.gov under docket number CFPB-2026-0018. You can read submissions from major banks, community lenders, trade associations, consumer advocacy groups, and individual borrowers. The official Federal Register notice with the CFPB’s 22 questions is also available on that site. The CFPB’s main page on TRID rules and guidance is at consumerfinance.gov.