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.