The FFIEC should “formally establish a transition period” in anticipation of the new TILA-RESPA integrated disclosures taking effect Oct. 3, ABA said in a letter to top financial regulators. The association asked that FFIEC issue formal guidance articulating how its agencies will examine and supervise mortgage originators in the months after TRID takes effect.
The transition period “would provide needed certainty to the credit markets and encourage lenders to continue to provide mortgage credit to qualified borrowers,” ABA said, adding that “the only way to realistically ensure an orderly transition is to confirm that supervisory standards work in tandem with lender efforts to refine and debug systems following the effective date.”
“While fine-tuning by the vendors is necessary for lenders to comply with the new rules, many lenders have yet to receive operational systems,” ABA added, noting that a transition period would accommodate the need for banks to adjust to vendor delays, changes and testing, as well as debugging systems after delivery and training staff.
Read the letter.