On June 3, 2015, the Consumer Financial Protection Bureau (CFPB) issued a statement reminding mortgage lenders that the new integrated loan disclosures required by Dodd-Frank become effective August 1, 2015. Because the TILA/RESPA Integrated Disclosure Rule, or TRID Rule, requires lenders to make substantial changes to their internal procedures for mortgage originations, the industry had requested that the CFPB grant a 60-day grace period before enforcement of the complex regulatory provisions. Many trade groups and lawmakers have joined together to push the CFPB for a reasonable “hold-harmless period” in order to ensure that consumers’ real estate closings will not be disrupted after the TRID implementation deadline. While the CFPB has not conceded to a grace period, the agency has stated that it will be “sensitive” to mortgage lenders making a good faith effort to comply with the rule. This falls short of an actual grace period and it will require an act of Congress to delay implementation of TRID.
Miller Nash Graham & Dunn has prepared a PowerPoint describing the TRID Rule and the new risk environment. For a copy of this presentation, please email us at BankLawMonitor@millernash.com.