On June 17, 2015, the Consumer Financial Protection Bureau (‘CFPB”) announced a delay for the implementation of the TILA-RESPA integrated Disclosure rule (“TRID”) until October 1, 2015. The previous deadline was August 1, 2015.
CFPB Richard Cordray released a statement that attributed the delay to “an administrative error,” stating:
“The CFPB will be issuing a proposed amendment to delay the effective date of the Know Before You Owe rule until October 1, 2015. We made this decision to correct an administrative error that we just discovered in meeting the requirements under federal law, which would have delayed the effective date of the rule by two weeks. We further believe that the additional time included in the proposed effective date would better accommodate the interests of the many consumers and providers whose families will be busy with the transition to the new school year at that time.”
The TRID rule — also known as the “Know Before You Owe” rule — requires mortgage lenders to provide two new documents to consumers applying for a mortgage loan: a Loan Estimate form and a Closing Disclosure form. The Loan Estimate must be provided to consumers applying for a mortgage loan three days after they submit an application. The Closing Disclosure form must be provided three days prior to closing.
On May 1, 2015, a bill to provide a temporary safe harbor for the mortgage industry from the enforcement of the TRID rule until January 1, 2016, was introduced in the U.S. House of Representatives (H.R. 2213).
In early June 2015, the CFPB announced that it was providing the mortgage industry with an open-ended grace period to implement the TRID rule. Mortgage Bankers Association chairman and CEO David Stevens told HousingWire that the grace period will be open-ended but should run through the end of 2015 at the very least.
HousingWire reported that a response to Cordray’s letter from U.S. Rep. Blaine Luetkemeyer, (R-MO), Chairman of the Housing and Insurance Subcommittee, and U.S. Rep. Randy Neugebauer (R-TX), Chairman of the Financial Institutions and Consumer Credit Subcommittee expressed disappointment that the CFPB had not granted the mortgage industry a formal hold-harmless period. A consortium of mortgage industry groups has urged Congress to pass H.R. 2213 to formalize a grace period.
The attorneys at Glass & Goldberg in California provide high quality, cost-effective legal services and advice for clients in all aspects of commercial compliance, business litigation and transactional law. Call us at (818) 888-2220, send an email inquiry to info@glassgoldberg.com or visit us online at glassgoldberg.com to learn more about the firm and to sign up for future newsletters.
