Archive

FINAL REVISIONS TO SERVICING RULES

On August 4, 2016 the Consumer Financial Protection Bureau (CFPB) published revisions to rules for servicers that went into effect on January 10, 2014. The CFPB issued proposed amendments to those rules in November 2014, and the final rule adopts many of the proposed provisions. This final rule clarifies, revises, or amends provisions regarding: Force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; Prompt crediting and periodic […]

CFPB FINALIZES TRID DELAY

On Tuesday the Consumer Financial Protection Bureau (CFPB) issued a final rule extending the effective date of the Truth-in-Lending Act/Real Estate Settlement Procedures Act Integrated Disclosures (TRID) rule to October 3, 2015. The original effective date was set for August 1, 2015. On June 24, 2015, the Bureau proposed a two month extension of the effective date to correct an administrative error that would have delayed the effective date of the rule by at least […]

TRID DELAY PROPOSAL

The Consumer Financial Protection Bureau (CFPB) has issued a 23-page proposed regulation to delay the Truth in Lending/RESPA Integrated Disclosures from August 1, 2015 to October 3, 2015.  The delay is appreciated, but some of the explanations are just weird. The delay occurred because a CFPB staffer forgot to send a notice to Congress 60 days prior to the August 1st effective date. By the time the error was discovered a two-week delay, until August […]

TRID DELAY

Today, within hours after the Consumer Financial Protection Bureau (CFPB) announced to 1,700 bankers at the ABA Regulatory Compliance Conference that there would be no delays in TRID (TIL/RESPA Integrated Disclosure Rule) implementation, CFPB Director Richard Cordray issued the following statement: “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 […]

TRID DELAY – NOT LIKELY

It is that season again. Every time we approach the effective date of a major regulatory change various financial institution associations make last-ditch efforts to delay the changes or the impact of the changes. The outcome is always the same – nothing changes. The Truth-in-Lending/RESPA Integrated Disclosures (TRID) changes are no exception. Recently the American Bankers Association (ABA) petitioned the Consumer Financial Protection Bureau (CFPB) to provide a grace period that would allow more time […]