Some breathing room… CFPB delays TRID

by: Michael Christians

On June 17^th the Consumer Financial Protection Bureau (“CFPB”) announced they would be issuing a proposed rule to delay the effective date of the TILA/RESPA Integrated Disclosure Rule (“TRID”). Yesterday we got our first look at that rule. In a press release accompanying the proposed rule, the CFPB had the following to say about the delayed implementation date:

“The Bureau is issuing the proposal to correct an administrative error that would have delayed the effective date of the rule by at least two weeks, until August 15^th at the earliest. The CFPB is proposing a new effective date of Saturday, October 3. The Bureau believes that moving the effective date may benefit both industry and consumers with a smoother transition to the new rules. The Bureau further believes that scheduling the effective date on a Saturday may facilitate implementation by giving industry time over the weekend to launch new systems configurations and to test systems.”

This is an interesting 11^th hour development and one I’m confident the industry as a whole is very receptive to. Following months of ignoring repeated requests from both loan originators and Congress to delay the August 1^st effective date, Director Cordray and the G Street Band blinked. Let’s break down what this means for your credit union.

First, if you are wondering what the administrative error was that prompted the delay it appears the CFPB missed a required deadline under the Congressional Review Act (“CRA”). The CRA requires agencies to notify Congress at least 60 days before a regulation becomes effective. Because of “an administrative error on the Bureau’s part in complying with the CRA”, the earliest TRID could take effect would be August 15^th.

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