Do not be fooled by false reports of another delay in TILA/RESPA Integrated Disclosure (TRID) requirements — the rule takes effect October 3. Lenders are busy running sample loan scenarios through their loan origination systems, calling vendors to troubleshoot problems, consulting with IT employees and getting ready for the dreaded deadline.
In the next few days, someone may advise you to not worry about the TRID deadline because CFPB Director Richard Cordray told members of Congress that there will be a “hold harmless” period. But Director Cordray said no such thing. When pressed during questioning at the House Financial Services Committee hearing today, he stated that there will be an informal grace period. However, this is not a free pass — October 3 is still the deadline for TRID compliance.
If you want to be able to sell the loans you originate to investors, and if you want to avoid becoming a defendant in a civil action by a consumer for violating the Truth in Lending Act, keep forging ahead with TRID compliance and be ready to go this Saturday.