June 17, 2015 - The CFPB has announced they will be issuing a proposed amendment to delay the effective date of the Know Before You Owe rule until October 1, 2015. Richard Cordray stated "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 GMLA is wondering what caused an agency of over a thousand people with a near unlimited budget, lawyers aplenty, that has issued thousands of pages of regulations to make an administrative error like this. Turning lemons into lemonade, Cordray added that the kids are going back to school is another good reason to delay TRID.
What about the millions of dollars spent by federal and state licensed lending institutions for TRID development and compliance activities? NO BRIGHT LINE FROM THE CFPB YET AGAIN! If we were the CEO's of these lending companies we'd call for Richard Corday's resignation. Let's all remember the CFPB has also been accused of employee discrimination.
Now OLD TRID News Posts:
June 24, 2015 - CFPB published it's proposed rule for public comment. The big news is another date change to October 3, 2015 instead of October 1, 2015 for TRID implementation. The 23 page proposed rule contains lots of date changing corrections for all the components that comprise the new TILA-RESPA rules. Those wanting to provide comments requested in the proposed rules will only have until July 7, 2015 to file them. We are left wondering why the CFPB has allowed such a short time period for comments. DOWNLOAD CFPB PROPOSAL
The CFPB proposal admitted error for TRID implementation delays. In the document the CFPB admits it failed to notify both houses of Congress and the Government Accountability Offices as required by law. There are more details being reviewed in this document by the GMLA. In our June 17, 2015 post to this page we questioned the transparency of the CFPB mega agency that freely operates without any accountability or oversight. Please watch for more information from the GMLA on this issue.
June 3, 2015 - Apparently the CFPB has modified their stance regarding enforcement of the new RESPA/TILA disclosure forms. Those testifying in favor of a delay at a House Financial Services Committee meeting in May likely pushed the CFPB to see the writing on the wall. The Consumer Financial Protection Bureau (CFPB) announced on June 3, 2015 that they would allow lenders additional time to become in complete compliance with TRID. The devil is in the details on what this truly means so we recommend your company continue full Implementation of the new rules.
CFPB Director Richard Cordray stated the delay came in response to considerable input received from the housing industry and said, "I have spoken with our fellow regulators to clarify that our oversight of the implementation of the Rule will be sensitive to the progress made by those entities that have squarely focused on making good-faith efforts to come into compliance with the Rule on time. My statement here of this approach is intended to ease some of the concerns we have heard about this transition to new processes in the coming months."
Here is a link to Cordray's Letter to Congress: June 3, 2015 Corday Letter To Congress
As usual we will all see if the CFPB creates a "bright-line" concerning TRID enforcement delays. As of the writing of this column CFPB has not put out any written guidance.
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