Removing Barriers Blog

CFPB Finalizes October 3 date of TILA-RESPA Integrated Disclosure Rule

The Consumer Financial Protection Bureau (CFPB) today issued its final rule moving the effective date of the TILA-RESPA Integrated Disclosures rule to October 3, 2015.  While the Bureau acknowledged in the final rule that the TILA-RESPA Final Rule and Amendments require “major operational changes for industry and close coordination among many different parties”, the CFPB nonetheless maintained the October 3, 2015 extension.  The final rule also included various technical corrections to the rule.

CUNA previously submitted a letter to the CFPB requesting a delay until January 1, 2016 the implementation of the TILA-RESPA Integrated Mortgage Disclosures Rule to allow for a smooth transition to the extensive rule given the magnitude, complexity, and expense of the rule.  CUNA further reiterated its continuing call to implement a safe harbor for legal liability and enforcement. 

CUNA continues its call for the CFPB to confirm that creditors that make five or fewer mortgages per year, as outlined in the rule’s supplementary information and the September 2014 Small Entity Compliance Guide, are exempt from the TILA-RESPA rule.  There currently exists an inconsistency between the text of Regulation Z and the supplementary information and Guide.

A copy of the final rule can be found here.  For more information please contact Andy Price.