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Director Richard Cordray announced today that the effective date of the
TILA-RESPA Integrated Disclosures Regulation will be extended until October 1st
from its original date of August 1st. CUNA has strongly advocated
for an extension of the effective date of the rule, and while we appreciate the
extension of the deadline, we still strongly advocate that there is an official
hold-harmless period for compliance until the end of the year. We will keep you
updated of any further changes in the rule’s effective date.
Director Richard Cordray announced that the effective date of the Know Before
You Owe rule, which includes the Truth-in-Lending Act (TILA) and Real Estate
Settlement Procedures Act (RESPA) Integrated Disclosures (TRID will be extended
until October 1, 2015 from its original date of August 1, 2015.
CFPB statement announcing the extended effective date, Cordray stated that the
additional compliance time is necessary to correct an administrative error
which would have delayed the effective date of the rule by two weeks, and for
the purpose of better accommodating the interests of the many consumers and
providers whose families will be busy with the transition to the new school
year at that time. It has been reported that the administrative error is that
the CFPB failed to comply with the Congressional Review Act’s requirement to
notify Congress at least 60 days before a regulation becomes effective.
in regards to the TRID rule, earlier this month CUNA brought to the attention
of Bureau staff a discrepancy related to the scope of the new requirements. The
final rule offers a different description of the scope of the rule than both
the guide that the Bureau issued in September 2014 to help small financial
institutions understand how to comply with the new rule and the supplementary
information that accompanies the rule. CUNA CEO Jim Nussle sent a letter
to the CFPB on Friday expressing our concerns about this and seeking clarity.
CUNA is seeking clarity about why the most recent Small Entity Compliance Guide
no longer states that the rule does not apply to loans made by a person or
entity that makes five or fewer mortgages in a calendar year. The previous
guide released in 2014 states, “consistent with the current rules under TILA,
the rule also does not apply to loans made by a person or entity that makes
five or fewer mortgages in a calendar year and thus is not a creditor.”
However, this language is absent from the most recent guide.
the previous language and final rule’s supplementary information many small
credit unions understood they are exempt from the new requirements if they
originate five or fewer mortgages per year, regardless of the number of
non-mortgage loans they originate. CUNA estimated that this discrepancy
could affect more than 700 credit unions, who would be exempt under the
definition originally provided by the CFPB.
continues to engage with the CFPB to seek clarification on this important
matter, and we appreciate that the Bureau’s discussions with us about this
issue. Additionally, CUNA has strongly advocated for an extension of the
effective date of the rule, and while we appreciate the extension of the
deadline, we still believe that an official hold-harmless period for compliance
needs to be implemented until the end of the year.
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