On Thursday, May 14th, key figures in the housing and mortgage industries brought a major issue with the rollout of TRID to the House Subcommittee on Housing and Insurance. The purpose was to urge House members to support a good-faith grace period for compliance with the TILA-RESPA Integrated Disclosure requirements that are slated to go into effect on August 1, 2015. The Dodd-Frank Wall Street Reform and Consumer Protection Act transferred the authority for both RESPA and TILA to the CFPB.
Mortgage lenders nationwide are finding it difficult to prepare for the implementation of such a dramatic new process. The preparation is made difficult due to the fact that many smaller organizations are turning to consultants and vendors for support. The compliance aspect of this process requires new software and system updates that are extremely costly for each company.
The new Integrated Disclosure forms are not permitted to be used prior to the August 1st implementation date meaning consumers, the industry, and the CFPB do not have a chance to test the new closing process in real time providing yet another pitfall to this initiative. With all the changes to technology platforms, staff training, and business practices, a test period is essential to ensure proper and effective compliance.
H.R. 2213 asks for leniency of the integrated disclosure requirements and the filing of any related lawsuit if: 1) the company or person has made a good-faith effort to comply with the requirements and 2) the conduct alleged to be in violation of the requirements occurred on or before December 31, 2015. This would allow all parties involved to appropriately test the new process and implementation of the rule without the risk of severe punishment. The industry now waits to hear if the House supports the grace period.
*This is not meant to be legal advice. Please seek legal counsel as you implement TRID. CMG Financial is dedicated to fully complying with all requirements in regards to TRID.