Removing Barriers Blog

CFPB to Reopen TRID/KBYO rules in response to CUNA Advocacy
Posted April 28, 2016 by CUNA Advocacy

In response to months of advocacy, today the CFPB sent a letter to industry trade associations, including CUNA, to announce that it will initiate a rulemaking in late July 2016 to address many of the ongoing issues and concerns over the implementation of the TILA/RESPA Integrated Disclosures (TRID) or Know Before You Owe (KBYO) rules.  

We’ve had ongoing discussions with the CFPB since the TRID rule became effective on October 3, 2015, and most recently outlined numerous concerns in a letter to Representatives Blaine Luetkemeyer and Randy Negebauer.  In that letter, we recommended numerous areas in need of clarification by the CFPB, especially the need to clearly allocate liability and responsibility for the various roles in the closing process, and ensure a properly functioning secondary market.

The CFPB has been reluctant to issue written guidance or amend its existing TRID rule. Until now, it has simply continued to urge industry to attempt to “work out” the issues, despite outcries from CUNA and the rest of the financial services industry.  We are pleased to see that the CFPB is now acknowledging the immense and complicated compliance burden that TRID is placing on credit unions, and beginning the process of amending it.

We will continue to work with the CFPB as it moves forward with this amendment process to ensure that it brings proper relief for credit unions.