CFPB Director Cordray announced through a letter to Congress that the Bureau would be “sensitive” to those making good-faith efforts to come into compliance with the TILA-RESPA Integrated Disclosure (TRID) rule, effective August 1, 2015.
It is not a “hold harmless” period that many industry leaders, including IBAT President and CEO Chris Williston, have called for time and time again. Adding to the woes, the CFPB did not clarify the meaning of “sensitive” nor elaborate on what constitutes a “good-faith effort.” This leaves many banks across Texas with the daunting task of finalizing loan processing software installation and training with less than two months before the effective date without any meaningful reprieve.
In the same announcement on its web page, the CFPB sought to “clarify misunderstandings” regarding the limited circumstances in which the TRID rule requires a revised Closing Disclosure and triggers a new waiting period. In a fact sheet, the CFPB stated that if one of three specific conditions are met, the lender would have to provide the borrower with a revised Closing Statement and reset the three-day review period mandated by the TILA-RESPA Integrated Disclosure rule. Other issues addressed up until closing, including the correction of errors or most changes to a payment amount, would not trigger a revised Closing Statement. Read the CFPB announcements here.