A Bit of Grace from the Consumer Financial Protection Bureau
The Consumer Financial Protection Bureau (CFPB) has finally agreed to bend under the strain of numerous requests from financial industry participants and 255 bi-partisan House members and 41 senators, who requested that the CFPB delay the implementation of the new Truth in Lending Act and Real Estate Settlement Procedures Act Integrated Disclosures (TRID) requirements. Although the TRID will still go into effect as of August 1, 2015, the CFPB has agreed to a grace period for enforcement actions against lenders that are making good faith efforts to comply with the TRID.
This grace period should not be interpreted to mean that lenders are not required to use the new forms. Lenders must still use the TRID forms as of August 1, 2015, but now lenders can breathe a bit easier knowing that they will have time to test their systems and work out any technical glitches that may arise with the use of the new forms.
The CFPB has a section on its website dedicated to the TRID implementation, including guidance documents and example forms. Please see here.
Although the CFPB has claimed that its guidance documents and the commentary to the new Rules provide all of the answers, we have found situations in which there is not a clear answer on where to include certain information on the TRID. Thus, it is reasonable to expect that the CFPB may be providing additional guidance and clarifications regarding the Rules after the August 1 implementation date. Stay posted for any updates.