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, the CFPB has announced the same approach it took with implementing the amendments to Regulations X and Z in early 2014, as well as other home lending-related rules. Director Cordray explained that he has spoken with other regulators, and enforcement efforts “will be sensitive to the progress made by those entities that have been squarely focused on making good-faith efforts to come into compliance with the rule on time.”
Note that this sensitivity to good-faith efforts to comply with the TRID rule does not extend to any efforts of borrowers to enforce those aspects of the TRID rule that permit private rights of action.
Should your institution require assistance as the August 1 deadline nears, please contact Spilman.