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MReport_July2015

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40 | Th e M Rep o RT O r i g i nat i O n S e r v i c i n g a na ly t i c S S e c O n da r y m a r k e t SERVICING The laTesT cFPB announces 'good Faith' grace Period For trid rule compliance With the August 1 deadline looming, the CFpB addresses industry concerns. t he Consumer Finan- cial Protection Bureau (CFPB) announced last month that a grace period will be in effect for those servicers attempting to comply in good faith with the TILA-RES- PA Integrated Disclosure (TRID) requirements that are scheduled to go into effect August 1. Both mortgage industry stake- holders (servicers in particu- lar) and lawmakers have been asking the CFPB to delay the implementation of TRID. In a letter to CFPB Director Richard Cordray dated May 20, a biparti- san coalition in Congress asked for a grace period, expressing concerns that "this complicated and extensive rule is likely to cause challenges during imple- mentation" that could "negatively impact consumers." While the CFPB did not push back the August 1 implementa- tion date of the rule, it attempted to ease some of those concerns by saying it would take into account a company's good faith effort to comply with the rule after it goes into effect. "We also delivered a letter to Members of Congress stating that our oversight of the implementa- tion of the Know Before You Owe mortgage rule (also known as the TILA-RESPA Integrated Disclosure rule) will be sensitive to the progress made by those entities that have been squarely focused on making good-faith efforts to come into compliance with the rule on time," the CFPB wrote on its blog. "We have spo- ken with our fellow regulators to clarify this approach. This is consistent with our approach in the implementation of the Title XIV mortgage rules." Cordray responded to the law- makers' letter on June 3, stating the Bureau's desire for a smooth transition and that since the rule was published in November 2013, the CFPB has made it a point to "engage directly and intensively with financial institutions and vendors through a formal regula- tory implementation project." That project includes inter-agen- cy coordination, the publishing of a "readiness guide" and other resources, publishing amend- ments and updates to the rule in response to industry requests, providing unofficial staff guid- ance, conducting webinars, and clarifying misunderstandings. The CFPB Director also pointed out in his response that the Bureau will continue to work with industry, consumer, and other stakeholders to sup- port implementation of TRID after August 1. Some mortgage industry leaders praised Cordray's response to the concerns expressed by lawmakers and those within the industry. "I thank CFPB Director Cordray for listening to the requests of CUNA, Congress, and others in our call for a safe harbor period through the end of the year for the enforcement of the TRID rule," said Jim Nussle, president and CEO of the Credit Union National Association (CUNA), released the following statement. "CUNA supports the CFPB's goal for transparency with the new disclosures helping consumers better understand mortgage terms, and now credit unions will be allowed the time they need to figure out the day- to-day aspects of complying with the rule without worrying about enforcement." National Association of Federal Credit Unions president and CEO Dan Berger, who along with his staff lobbied Congress and met with Cordray several

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