We made this decision to correct an administrative error that we just discovered in meeting the requirements under federal law, which would have delayed the effective date of the rule by two weeks. We further believe that the additional time included in the proposed effective date would better accommodate the interests of the many consumers and providers whose families will be busy with the transition to the new school year at that time.ABA welcomed the news. "This extension will help protect consumers from disruptions during a traditionally busy period for home purchases," said ABA President and CEO Frank Keating. "It will also help to ensure new loan origination systems and compliance software under development by lenders and the vendors on whom they rely will be adequately installed and debugged, and staff training completed, before the effective date."
ABA has engaged in a months-long advocacy effort to persuade the CFPB to delay the rule or provide a hold-harmless period after the rule takes effect for lenders that make good-faith efforts to comply. In a survey shared with the bureau, ABA found that a large majority of banks did not expect to receive their new TRID-compliant systems from vendors until July or later, leaving little to no time to test systems and train staff. By extending the effective date, the CFPB will provide additional time to install and test new systems while removing the risk of civil litigation during the two-month window.
Keating also thanked the CFPB for its announced intent to take good-faith compliance efforts into account in its initial supervisory and enforcement approach. "The TRID rules remain among the most complex with which the banking industry has had to comply, and the quality of compliance should be expected to improve based on the industry's learning curve once systems go live," he said.
Read Cordray's statement.