We recently reported on the TILA-RESPA Integrated Disclosure Rule (TRID), scheduled to go into effect later this year. On June 9, several trade groups, including the American Bankers Association and the Mortgage Bankers Association jointly authored a letter to the House Financial Services Committee, urging the passage of H.R. 2213, introduced in the House on May 1, 2015, which would “provide a reasonable hold-harmless period for enforcement of” TRID “for those that make good-faith efforts to comply.” According to H.R. 2213, this “Enforcement Safe Harbor” would be in place until January 1, 2016.
The Consumer Financial Protection Bureau has already indicated that it would be “sensitive” to progress made by entities that make good-faith efforts to comply. However, the trade groups potentially affected by TRID seek “more certainty” that their good-faith compliance efforts would protect them from exposure to litigation, at least for a brief period after TRID becomes effective.
In the meantime, the CFPB has issued a compliance guide, timeline, and additional information regarding the integration of TRID, all of which are available at the CFPB’s website: http://www.consumerfinance.gov/regulatory-implementation/tila-respa/.