CFPB Postpones TRID Implementation Date from August 1 to October 1, 2015
In welcome news to the industry, the Consumer Financial Protection Bureau (CFPB) announced on June 17, 2015 that it will delay the effective date of TRID (the TILA-RESPA Integrated Disclosure rule) until October 1, 2015. Director Richard Cordray announced the CFPB’s intent to issue a proposed rule change to delay the effective date, with opportunity for public comment.
The Director vaguely referenced an unidentified, but recent discovery of “an administrative error” that would have caused a two-week delay in the effective date as the reason prompting the rule change. The CFPB further explained the additional time will “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 [of the original August 1 effective date].” The Director confirmed a final decision on the rule change is expected shortly after the close of the public comment period.
The CFPB’s announcement came as a shock on the heels of the CFPB’s proclamation two weeks ago that it would only interpose a short delay in the scheduling of examinations for TRID compliance, but would not push the August 1 effective date. Debate continues as to whether the CFPB’s proclamation amounts to a “grace period” or if it amounts to nothing.
The two-month delay proposed by the CFPB falls shy of the five-month delay recommended by 290 congressional leaders in a May 20 letter to Director Cordray. However, the delay gives an additional 1,464 hours for lenders, settlement service providers and their technology partners who are working tirelessly to update and integrate systems and processes to ensure TRID compliance. The CFPB’s announcement ignored the months’ long campaign by industry stakeholders for a rule delay given the complexity of the changes and the technology challenges; the proposed amendment is expected to acknowledge the industry’s interest.
The tenor of the announcement may indeed provide much fodder for industry bloggers. Some industry experts observe that the CFPB’s nod to the consumer interest as the reason for delaying the rule merely confirms the agency’s role as enforcer, not regulator.