We previously reported on the remarks made by Consumer Financial Protection Bureau Director Richard Cordray on May 12 that the CFPB would not voluntarily change the August 1 effective date for the TILA-RESPA Integrated Disclosure Rule (TRID). This officially changed on June 24 with the CFPB’s issuance of a proposed amendment to TRID, postponing its effective date from August 1 to October 3.
The CFPB issued the proposal to correct an administrative error. Specifically, the CFPB recently discovered that it inadvertently had not submitted the rule report to Congress as required. Upon discovering its error, the CFPB submitted the rule report to both Houses of Congress and the Comptroller General of the Government Accountability Office on June 16, 2015. However, under the Congressional Review Act, the TILA-RESPA Final Rule cannot take effect until, at the earliest, August 15, 2015 – two weeks after the currently-scheduled effective date.
In light of the administrative error, as well as the extent of “unique implementation challenges for industry, requiring major operational changes” that even the CFPB recognizes, it wisely decided to propose that TRID’s effective date be delayed to October 3. The proposal is open for public comment until July 7, and the CFPB expects to make its final decision shortly thereafter.