Information and recap provided by Jean Comeau
Last month I attended an Eastern Massachusetts Compliance Network meeting where some of the topics discussed by Ruth Dillingham, Owner of Dillingham Consulting LLC, included TRID, Seller Impersonation, and Financial Abuse of Elders. Here are some of the key take aways on each topic and some helpful links.
TRID
The CFPB issued a Request for Information (RFI) on TRID and Mortgage Credit with public comments due on August 10, 2026. They received over 300 responses. Key focus areas were:
TRID Timing Requirements
Reviewing rules for Loan Estimated and Closing Disclosures, replacing tight TRID timing requirements, addressing pre and post consummation timing overlaps.
Other TRID Requirements and Tolerances
Evaluating fee increase tolerances (such as 0 percent and 10 percent thresholds for transfer taxes, appraisals, and related fees) and the operations costs of fee cures. Assessing electronic signature and delivery requirements. Streamlining construction loan disclosures.
Right of Rescission and Reverse Mortgages
Rescission: Examining whether combining pre-consummation TRID waiting periods with post-consummation rescission delays refinance funding, and potentially exempting rate and term or cash out refinances.
Reverse Mortgages: Integrating and streamlining TILA and RESPA disclosures, altering Total Annual Loan Cost (TALC) table assumptions, and adding visual balance-growth charts for elderly applicants.
Here are the links to the RFI and the public comments that were received:
Seller Impersonation Fraud
This occurs when a criminal pretends to be the real owner of a property to sell it or take out loans against it.
Fun fact, according to American Land Title Association (ALTA), roughly 59% of title companies reported seller impersonation attempts.
How it Works
Scammers look for high-risk properties like vacant land, second hoes, rental properties, or homes with no active mortgage.
They gather public records of the real owner and create fake driver’s licenses, passports, or digital documents that are often enhanced using AI.
The fake seller usually claims they are out of state or country and refuses to meet in person and insists on using a mobile or seller-chose notary.
Once the sale of the fraudulent mortgage transaction closes, the funds are wired to the scammer’s account, and the fraud is often not discovered until months later.
Common Red Flags
The home is vacant, non-owner occupied or has a different tax mailing address than the property address.
The seller demands a fast, below-market cash sale.
The seller avoids audio or video calls and communicates only via text/email or fails multi-factor authentication.
The notary is out-of-state or wiring instructions point to a third-party or unusual bank account.
Read More from ALTA:
https://www.alta.org/file/ALTA-Seller-Impersonation-Handout
Financial Abuse of Elders
Financial abuse of elders in mortgage lending involves deceiving, coercing or manipulating an older adult into taking out a high-cost mortgage, refinancing, or reverse mortgage or misusing a Power of Attorney to take equity aways from their home.
How it is Done
Targeting homeowners aged 62 or older to strip equity through predatory reverse mortgages with excessive fees and high interest rates.
Coercing an elder into signing over property titles or adding unauthorized names to the deed.
Misuse of a POA to pull cash-out or redirect loan proceeds without owner’s consent.
Forging signatures on loan documents.
Where to Report
Adult Protective Services, local law enforcement or the Department of Justice elder Justice Initiative https://www.justice.gov/elderjustice/financial-exploitation-0
