On October 1, CFPB Director Richard Cordray, on behalf of the FFIEC, responded to correspondence from the American Bankers Association and other trade associations seeking guidance as to their compliance with the Bureau’s Know Before You Owe TILA-RESPA Integrated Disclosure Rule, which will become effective on October 3, 2015. Per Director Cordray’s letter, the FFIEC’s member agencies’ examiners “will expect supervised entities to make good faith efforts to comply with the Rule’s requirements in a timely manner.” Moreover, examiners will take a number of factors into consideration in determining compliance with the Rule, including (i) an institution’s implementation plan; (ii) an institution’s training of its staff; and (iii) how an institution handles any early technical problems or other implementation challenges.