Monthly Archives: June 2015

CFPB Issues Proposed Rule Regarding Delayed Implementation of TRID Rule

Earlier this week, the Consumer Financial Protection Bureau (“CFPB”) issued its proposed rule regarding delayed implementation of the TILA-RESPA Integrated Disclosure (“TRID”) Rule. The new date the CFPB selected is October 3, two days later than the previously announced date. The CFPB explained that “scheduling the effective date on a Saturday may facilitate implementation by […]

CFPB Announces Proposal to Delay TRID Rule Until October

Although the Consumer Financial Protection Bureau (“CFPB”) announced two weeks ago that it would not delay implementation of the combined TILA-RESPA Integrated Disclosure (“TRID”) rule, yesterday the CFPB reversed course. Director Cordray issued a statement that it will propose an amendment to delay the rule’s effective date from August 1 to October 1. The full […]

CFPB Mortgage Loan Originator Compensation Rule Applied to Marketing Services Agreements

Last week, the Consumer Financial Protection Bureau (“CFPB”) extended the Mortgage Loan Originator Compensation Rule (the “Comp Rule”) to a marketing services agreement. You will recall that the CFPB assumed enforcement responsibility for the Comp Rule in July 2011 and subsequently revised the rule in connection with other mortgage-lending rulemaking. In the Guarantee Mortgage Consent […]

CFPB Offers Limited Reprieve for TRID Rule Compliance, But Says No to Delayed Enforcement

The Consumer Financial Protection Bureau (“CFPB”) has declined to delay enforcement of the TILA-RESPA Integrated Disclosure (“TRID”) rule, which takes effect for applications received on or after August 1, 2015. The CFPB has refused to delay enforcement or offer a waiting period during which the TRID rule would apply, but enforcement would be limited. Instead, […]