On June 17, the director of the Consumer Financial Protection Bureau (CFPB), Richard Cordray, announced plans to delay the effective date of the TILA-RESPA Integrated Disclosure Rules (TRID) or the Know Before You Owe Rules from August 1, 2015, to October 1, 2015. The decision to delay the effective date is shocking to the mortgage industry because the CFPB previously denied many requests to implement a later start date or hold-harmless enforcement period.
Apparently, the reason for the delay is to correct an administrative error that was recently discovered by the CFPB. Cordray added, “We further believe that the additional time included in the proposed effective date would better accommodate the interests of the many consumers and providers whose families will be busy with the transition to the new school year at that time.”
A public commenting period regarding this delayed effective date will be provided by the CFPB and a final decision will follow.
It is unclear how this new delay will impact a recently introduced bill that implements a hold-harmless period for TRID-related enforcement actions. If enacted, H.R.2213 will prohibit TRID enforcement actions until January 1, 2016.
The TRID Rules are a monumental shift for the mortgage industry because they consolidate four existing disclosures currently required under TILA and RESPA into two forms: a Loan Estimate and Closing Disclosure.