Archive

CHANCE TO BREATHE

I lot of people seemed to think that once the August 1 TRID deadline arrived life would be much easier. Well today is August 1, and the future doesn’t look any easier. TRID has been delayed until October 3, 2015; New interagency flood insurance regulations are effective, in large part, on October 1, 2015, with the new escrow rules unfolding on January 1, 2016; The new Military Lending Act regulations, which look like the real […]

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 […]

FINAL RULE REVISES TIL AND RESPA

On January 18, 2015 the Consumer Financial Protection Bureau (CFPB) approved final changes to Regulations X and Z. The changes are effective on August 1, 2015. The final rule: Extends the timing requirement for revised disclosures when consumers lock a rate or extend a rate lock after the Loan Estimate is provided; Clarifies placement of the Nationwide Mortgage Licensing System and Registry ID (NMLSR ID) on the integrated disclosures; Permits certain language related to construction […]