Last week, IBAT President and CEO Chris Williston, along with the executives of Texas Land Title Association and Texas Bankers Association, signed an open letter to the U.S. House of Representatives in support for H.R. 3192 (Homebuyers Assistance Act). If passed and signed by the President, this legislation would provide a hold-harmless period until February 1, 2016 for mortgage lenders making a good-faith effort to comply with the CFPB's new TILA-RESPA Integrated Disclosure (TRID), which became effective last Saturday, October 3, 2015. The letter specifically recognizes Reps. French Hill and Brad Sherman for introducing the bipartisan legislation.
During the regulatory panel held at IBAT’s Convention two weeks ago, all of the representatives of the federal banking regulators (OCC, Fed and FDIC) said that until the end of the year they will focus more on the good-faith efforts community banks have taken to prepare for TRID rather than the results. On Friday, the FDIC confirmed its comments in guidance issued regarding its initial supervisory expectations with TRID. Lastly, on September 29, CFPB Director Cordray appeared before the House Financial Services Committee to say that the CFPB was not looking for perfection on day one. While these statements assure some level of regulatory relief, they do not lessen the possibility of litigation, which would likely cause unnecessary and costly delays for consumers, and a disruption of the housing market.
“Texas community banks and their settlement service providers have made good-faith efforts to comply with TRID by the implementation date, but they need time to test these efforts in real-world settings without the threat of litigation,” said Williston. “While we appreciate the regulators’ soft-landing approach to TRID, borrowers and the mortgage lending industry need the four-month hold-harmless provision of H.R. 3192 to openly test and tweak lenders’ and servicers’ good-faith efforts without fear.”
As reported in last week’s Bottom Line, IBAT joined the same associations on a letter regarding H.R. 3192 to House Financial Services Chairman Jeb Hensarling. IBAT encourages members to write and call your members of Congress and urge their support of H.R. 3192.