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#2021294 - 06/18/15 06:46 PM
Re: Effective Date Delayed
trying_to_comply
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Platinum Poster
Joined: Oct 2009
Posts: 604
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Why don't I feel a sense of relief with this announcement?
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#2021297 - 06/18/15 06:48 PM
Re: Effective Date Delayed
RobinB
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Platinum Poster
Joined: Aug 2010
Posts: 528
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Maybe they should read the diversity standards rule they just finalized. I guess it applies to everyone but them.
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#2021310 - 06/18/15 07:14 PM
Re: Effective Date Delayed
trying_to_comply
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Power Poster
Joined: Oct 2009
Posts: 9,234
OK
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My biggest complaint in the entire TRID mess is this: the whole "idea" behind TRID is that the old way of doing things was confusing for the consumer, so we must clean it up so that these consumers can understand the disclosures. Does anyone on BOL think that a Loan Estimate is easier to understand than a Good Faith Estimate or early TIL or that a Closing Disclosure is easier to understand than a HUD-1 or TIL Disclosure Statement? Not saying they're harder necessarily either....just that people either are inclined to understand such a disclosure or they're not......i think our average customer would think not much has changed, if they care at all. So what greater purpose is getting served here? We all got to read 10 million words, 95% of customers still won't care nor understand their disclosures, and the sun will go down tonight as every night.
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I'm fixin' to fix that.
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#2021312 - 06/18/15 07:16 PM
Re: Effective Date Delayed
raitchjay
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Gold Star
Joined: May 2005
Posts: 298
Maryland
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95% of customers still won't care nor understand their disclosures, and the sun will go down tonight as every night. That's the truth.
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#2021318 - 06/18/15 07:20 PM
Re: Effective Date Delayed
trying_to_comply
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Power Poster
Joined: Oct 2009
Posts: 9,234
OK
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Actually, i agree with that. They are harder to understand. (So Congress, mission accomplished i guess.)
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I'm fixin' to fix that.
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#2021329 - 06/18/15 07:40 PM
Re: Effective Date Delayed
trying_to_comply
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10K Club
Joined: Nov 2002
Posts: 20,656
The Swamp
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I still don't understand how they had roomfuls of test consumers who came to the conclusion that this was the way to go...somehow I feel they were overwhelmed and just nodded in agreement to everything!
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My opinion only. Not legal advice. Say you'll haunt me - Stone Sour
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#2021352 - 06/18/15 08:23 PM
Re: Effective Date Delayed
trying_to_comply
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100 Club
Joined: Apr 2013
Posts: 110
Texas
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the administrative error cited is the CFPB's neglect to issue a notice in line with the Congressional Review Act 60 days before the rule takes effect. They basically "forgot" and had to file for a 2 week delay. This 2 week delay requires a period of Notice an Comment - so they decided to go with a 2 month delay.
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#2021366 - 06/18/15 08:58 PM
Re: Effective Date Delayed
trying_to_comply
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Junior Member
Joined: Sep 2009
Posts: 28
Texas
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Can I ask for a two week or two month delay to fix an administrative error when they arrive to do their exam? I think not and I bet I can't use that for a response to an error either.
Why wasn't I content being a teller all those years ago? I think a teller's life has gotten a little easier and I am absolutely sure our compliance jobs have not.
Thanks for letting me vent.
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#2021376 - 06/18/15 09:12 PM
Re: Effective Date Delayed
Truffle Royale
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Member
Joined: Mar 2014
Posts: 76
Washington
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[quote=Truffle Royale]I foresee the problem being the fact that management and employees alike will say 'well, don't have to worry about that now. Let's turn our attention to (inset a project.) That leaves me sounding like the little boy who cried wolf.
Exactly! I was just getting the lending staff to take me seriously. Now I will have to get them re engaged in September because lenders and processors only work in the "today world".
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I'm not sure about I'm sure...
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#2021486 - 06/19/15 01:51 PM
Re: Effective Date Delayed
trying_to_comply
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Diamond Poster
Joined: Sep 2011
Posts: 1,651
A CU, Where Regs Don't Apply
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The lenders are so used to ignoring me, that of the four people I sent the "announcement" to, only one (and she's over mortgage servicing, the least relevant of the areas contacted) has even opened the email. The relevant parties (the department heads and lending VP) go on thinking it's still 8/1.
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Someone's about to get horned!
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#2021497 - 06/19/15 02:16 PM
Re: Effective Date Delayed
Carter's Mom
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Diamond Poster
Joined: Sep 2008
Posts: 2,481
Midwest
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Is there any likelihood that they will let us begin using the new forms Aug 1 anyways... just to get used to the process? I'm guessing no, but keeping my fingers crossed. I was ready to check this project off of my list. :-) I'd like to see this. I understand that there are MANY people who have not received updates from their software vendors. We are fortunate to have received the updates and been testing, testing, testing, and testing. I do feel we are ready as long as we get another update from our vendor to fix a couple of things. I am on the fence. I like the extra time but also was ok with the 8/1 date as well. :dodges rock throwing:
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#2021503 - 06/19/15 02:35 PM
Re: Effective Date Delayed
Matt_B
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Power Poster
Joined: Sep 2004
Posts: 5,249
out of the frying pan...
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The lenders are so used to ignoring me, that of the four people I sent the "announcement" to, only one (and she's over mortgage servicing, the least relevant of the areas contacted) has even opened the email. The relevant parties (the department heads and lending VP) go on thinking it's still 8/1. When I told our CAO about it she replied, "Well that's great, but for the love of God do NOT tell anybody else!"
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You call it ADD. I call it multi-tasking.
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#2021504 - 06/19/15 02:35 PM
Re: Effective Date Delayed
Carter's Mom
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10K Club
Joined: Jul 2001
Posts: 84,498
Galveston, TX
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Is there any likelihood that they will let us begin using the new forms Aug 1 anyways... just to get used to the process? I'm guessing no, but keeping my fingers crossed. I was ready to check this project off of my list. :-) Not a chance.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2021517 - 06/19/15 02:52 PM
Re: Effective Date Delayed
trying_to_comply
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Gold Star
Joined: Oct 2014
Posts: 291
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Any idea when the proposed amendment to delay the effective date will be approved/final?
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Say what you mean, mean what you say, but don't say it mean.
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#2021540 - 06/19/15 03:29 PM
Re: Effective Date Delayed
trying_to_comply
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10K Club
Joined: Jul 2001
Posts: 84,498
Galveston, TX
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After the comment period expires.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2021572 - 06/19/15 04:15 PM
Re: Effective Date Delayed
trying_to_comply
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Gold Star
Joined: Oct 2014
Posts: 291
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When does it expire?
_________________________
Say what you mean, mean what you say, but don't say it mean.
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#2021589 - 06/19/15 04:53 PM
Re: Effective Date Delayed
trying_to_comply
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Diamond Poster
Joined: May 2011
Posts: 2,004
Idaho
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The comment period hasn't even opened yet.
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All opinions are my own, not my employer's
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#2021597 - 06/19/15 05:25 PM
Re: Effective Date Delayed
Truffle Royale
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100 Club
Joined: Nov 2012
Posts: 105
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I foresee the problem being the fact that management and employees alike will say 'well, don't have to worry about that now. Let's turn our attention to (inset a project.) That leaves me sounding like the little boy who cried wolf. I've already had this happen! And we are one of the banks still waiting on system updates so no testing has been completed.
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My views only.
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#2021606 - 06/19/15 05:43 PM
Re: Effective Date Delayed
trying_to_comply
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Power Poster
Joined: Oct 2009
Posts: 9,234
OK
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I'm sure in 5 years, a monstrous new regulation combining Reg. Z and RESPA will come down the pike and we'll be in this boat again, because "simplifying" regulations into something actually workable is not a strength of our Congress and the CFPB. So they'll hail it as a great, new, simplified thing that will be great for the industry; meanwhile, all of us will retire en masse.
_________________________
I'm fixin' to fix that.
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