Clients and Friends,
You may have already seen this, but I want to make sure you know that the CFPB has announced a proposed rule to delay the effective date of TRID to October 1, 2015. They stated that their reasons for this delay were an administrative error that would have, at a minimum, delayed the effective date by two weeks, and their desire to push back the effective date past the busy closing months of August and September. This is great news for the industry, which has lobbied for a delay, as it gives more breathing room to conduct testing, training, and tie up the loose ends before the effective date.
But don’t take your foot off the gas just yet. This is only a proposed delay, which means it can change before it’s final. Although I expect the two months to be finalized, it is possible that the CFPB will finalize a shorter time period. The minimum delay based on the administrative error is only two weeks. And I would expect the consumer advocacy groups to weigh in strongly on this proposal. And even if it is delayed by two months, the two months will fly by very quickly.
The proposed rue has not yet been posted, though I am keeping an eye out for it. Here is the link to the press release. http://www.consumerfinance.gov/newsroom/statement-by-cfpb-director-richard-cordray-on-know-before-you-owe-mortgage-disclosure-rule/
Also, many of you have asked me incredulously, “what did you do wrong?!” I thank you for your unwillingness to believe that I could have caused this error. I have heard that this error was a delay in filing a report to Congress, which happened after the effective date. So, no, I did not cause this error. Although I suppose that this means you won’t be thanking me for causing the delay with a bottle of wine or champagne, I am happy that you can continue your confidence in my ability to finalize 1,900 page rules without administrative errors.
Please let me know if you have any questions.