CFPB Declines Congressional Appeals for TILA-RESPA Grace Period
In an April 22 letter released yesterday, Consumer Financial Protection Bureau Director Richard Cordray declined congressional appeals to provide a grace period for enforcement of the TILA-RESPA integrated disclosures that come into force on Aug. 1.

“[E]valuating the scope of potential implementation challenges and appropriate responses prior to the effective date is unnecessarily speculative,” Cordray told Rep. Blaine Luetkemeyer (R-Mo.), one of the lawmakers who has advocated for a grace period. Instead, Cordray said the bureau would “answer questions, provide guidance and evaluate any issues industry and consumers experience as the [rule] is implemented.”

God Bless the CFPB.

Bless wouldn't have been the word I would have used.

Cordray got his appointment for being anti-bank and as far as I'm concerned he's lived up to that reputation from day 1.

That is just nasty.

In 2010, wasn't there a 4 month grace period for the new RESPA rules? It would make a lot of sense to start examining the new TRID rules Jan 1 2016.

Could not have said it better! Sheer arrogrance is astounding.

There are no more regulators! but "enforcers." IMHO.

Exactly! Take a look at the threads and questions on just the 2010 changes. What possible harm could a six month grace period be? The biggest question is how will these changes really help any consumer as these guys already know that 70% or more do not shop using current forms at all. So where is the urgency to turn this on its head?

Change for the sake of change!

Oh please. How long did they give the industry to address this? During a recent poll on BOL how many banks haven't even started yet on understanding the implications of the new regulations. Plus most examiners still don't even understand the 2010 changes. Calling the CFPB arrogant is a little like calling the kettle black.

Understanding the the rules, commentary, and other guidance material from the CFPB is one thing. Implementing new systems, controls and addressing the necessary training needs is another. Also, getting third party vendors, attorneys, real estate agents and others on board is will present some unique challenges of it's own (especially in regards fees in the expanded 0% tolerance bucket and the timeline for providing the Closing Disclosure).

If many banks, brokers, or others have not even began to take steps toward getting ready for this massive change to consumer mortgage disclosures, how far along can we expect these other parties to be on August 1st?

I believe the key to complying with this rule is going to be great technology and effective controls that can be tested and verified prior to implementation, setting expectations with vendors and attorneys early, timely and to the point training, and diligent management response to any issues that expose the bank to RESPA/TILA's sharp white teeth.

I was personally crossing my fingers for a short grace period.

Just because "many banks haven't even started yet" doesn't mean the compliance personnel within those banks haven't been working their tails off trying to get ready. Getting management, loan staff, vendors, etc. on board as well as getting the new processes in place is a completely different matter, and many of us are being somewhat forced into last-minute preparations by our software.

A grace period would have been nice.

I would agree most compliance staff have been working hard trying to understand the new rules. It is hard to get everyone on board.

I am lucky enough that we do have updates from our software company so we can begin testing. I will say after running test transactions it makes understanding the details a little easier to see how they are actually playing out onto the new forms.

I grace period would be nice just to get all the kinks worked out.

There were six of us here that went to a one day seminar - and five of us going to another 2 day seminar the end of the month. I know that our software company has things in place to begin testing. Looks like June and July will be very busy. Luckily my vacation isn't scheduled until the end of August.

I posted it somewhere else, but don't remember where, on this topic...just so you know (and I realize it could change) our FDIC regional office said regardless of a bona fide 'break-in' period or not...they would not judge harshly early on in the new game.

It at least made me feel better as we are ALL facing last minute software and realtime issues. We may basically understand the changes, but as those of us in the trenches are all too aware of...that's only the tip of the iceberg.

We're still trying to figure out how to run a double process for old docs and new docs for those first few weeks. With such a tiny deparment it's not really practical to designate certain processors to handle each kind.

I had to run two separate systems in 2010 to accommodate pre and post implementation date applications so that was the first question I asked my software provider. Lo and behold, this time, the system will generate docs based on the application date. whew!

But said system didn't send out the update on the promised delivery date. Nor has management selected a third party vendor. Hopefully the main players won't have forgotten everything they learned in training last month when testing finally can start.

Our system is actually the easy part of the double process - it will issue the applicable docs based on application date, too. (YAY for something easy about this!) Our difficulty is going to be making sure the human aspect understands which loan falls under which rules and which docs they have to produce on what timeline.

ETA: Again, a grace period would have been really nice.

While it would be interesting to see Congress show the CFPB that it does have some authority here, I just don't see this happening.

That said, there is a bill to provide some protections to lenders. https://www.congress.gov/bill/114th-congress/house-bill/2213?q=%7B%22search%22%3A%5B%22hr2213%22%5D%7D

ICBA reporting that more members of Congress and industry groups are asking again. I'm not optimistic...thankful our software providers seem to be on the ball and we're running test transactions already...

Anyone else believe the ultimate goal of the CFPB is 6-8 "mega" banks that they supervise directly and no other FIs?