The Consumer Financial Protection Bureau has promised to be “sensitive to good-faith efforts” of banks to comply with its new TILA-RESPA Integrated Disclosure Rule, known as TRID, which will take effect on Oct. 3. A coalition of industry advocates says now the Federal Financial Institutions Examination Council needs to ensure that prudential regulators are as “sensitive” as the CFPB has promised to be. The coalition is made up of the American Bankers Association, the Independent Community Banker of America and 16 other industry advocates.
“Industry stakeholders have undertaken extensive efforts to comply with these rules,” the coalition said in a letter to the FFIEC on Sept. 8. “But, even now, they are discovering significant compliance issues. These discoveries raise liability concerns that cannot be realistically resolved before the October 3 deadline, as many will require formal authoritative guidance.”
The FFIEC should formally implement a clearly articulated transition period for TRID, said the trade groups. It should “establish predictable regulatory restraint by enunciating clear guidelines that, if met in good faith, would afford institutions with enforcement and examination relief for a reasonable time period following October 3,” they said.
In June, bankers and industry advocates applauded the CFPB for delaying TRID’s effective date until October 3. The effective date had been August 1.
TRID is the result of a years-long effort to combine Truth in Lending Act and Real Estate Settlement Procedures Act disclosures.