On July 21st, the CFPB issued the final rule delaying the effective date for implementation of the TILA-RESPA Integrated Disclosures until October 3, 2015. Click here to learn more about the delay decision.
CFPB Proposes Delay to TRID Start Date
On Wednesday, June 17th, the Consumer Financial Protections Bureau (CFPB) announced a proposed amendment to the start date of the Know Before You Owe Mortgage Disclosure rule and use of the TILA-RESPA Integrated Disclosures, pushing it back from August 1st to October 1, 2015.
The start date amendment was made after the CFPB failed to meet the 60-day notice to Congress requirement under the Congressional Review Act. While it is only required to delay the start by two weeks because of the failure to notify, Director Cordray indicated that they would push the start back a full two months in order to “better accommodate the interests of the many consumers and providers whose families will be busy with the transition to the new school year” during late August and September, the time when the new rule would have had its initial impact.
The announcement does not indicate when the extension might be approved, saying only that the public will have an opportunity to comment on this proposal “and a final decision is expected shortly thereafter.”
ALTA issued a statement by its CEO, Michelle Korsmo, who praised the CFPB for suggesting a 2-month, rather than a 2-week, extension. She also took the opportunity to urge the CFPB to remove the ‘optional’ label of title insurance on the new TRID forms. “Telling a consumer that owner’s title insurance is ‘optional’ will mean that homebuyers may be dissuaded from purchasing the same protection that lenders receive from a title insurance policy. The CFPB’s disregard of the protections afforded by an owner’s title insurance policy is a disservice to the consumers they represent.”
While the delay is a welcome respite, we encourage our agents to continue to work toward Best Practices compliance and TRID readiness. We will keep you informed of any new developments.
Getting ready for the TILA-RESPA Intergrated Disclosure
As you may know, changes are coming again to the HUD Settlement Statement and related closing disclosure documents. We want you to be prepared for the new rules and new forms that will go into effect on October 3rd, 2015. To that end, Sue Ellen Rogal, Underwriting Counsel in our Boston office, has put together the following memo, together with a plan for future informational bulletins and webinars. If you have any questions about the new Loan Estimate and Closing Disclosure forms, please click here to contact Attorney Sue Ellen Rogal.