CFPB finalizes TRID effective date

by: Michael Christians

Today the Consumer Financial Protection Bureau (“CFPB”) issued a final rule delaying the effective date of the Integrated Disclosure Rule (“TRID”) to Saturday, October 3, 2015. A copy of the CFPB’s 40-page rule can be found here.

In addition to delaying the effective date, the final rule makes clear that the CFPB will not be instituting a formal grace period or allowing for a dual compliance period. Without a formal grace period your credit union remains subject to both compliance and legal risk for non-compliance after October 3^rd. However, the final rule reiterates comments made by Director Cordray to members of Congress in his letter of June 3rd: 

“Our oversight of the implementation of the Rule will be sensitive to the progress made by those entities that have squarely focused on making good-faith efforts to come into compliance with the Rule on time.” 

In addition, since the CFPB is not allowing for a dual compliance period, your credit union may only use the new Loan Estimate and Closing Disclosure on applications received on or after October 3^rd. For applications received prior to the effective date continue to use the Preliminary Truth-in-Lending Disclosure and Good Faith Estimate as applicable. Then as those transactions are consummated (likely after the effective date), use the Final Truth-in-Lending Disclosure and HUD-1 Settlement Statement at closing.

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