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 15, was required. The CFPB originally announced a delay until October 1st because “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 proposal further delayed the effective date until October 3rd because October 1st is a Thursday and the CFPB believes “scheduling the effective date on a Saturday may allow for smoother implementation by affording industry time over the weekend to launch new systems configurations and to test systems. A Saturday launch is also consistent with existing industry plans tied to the Saturday August 1 effective date.”
  • The proposal also acknowledges that “in recent weeks, the Bureau has learned that delays in the delivery of system updates have left creditors and others with limited time to fully test all of their systems and system components to ensure that each system works with the others in an effective manner.” Ironically I have told thousands of bankers over the last twenty months that no matter how much time the CFPB gives loan origination software vendors the vendors will need an additional two months.

The comment period ends on July 7, 2015.
A copy of the proposal is available here.