WASHINGTON–A group of nearly two-dozen trade associations, including NAFCU and CUNA, have sent a letter of thanks to Sen. Tim Scott (R-SC) and Sen. Joe Donnelly (D-IN) thanking them for introducing S. 1711, a bipartisan companion bill to H.R. 2213, which will provide a reasonable hold-harmless period through the end of the year following the Oct. 3 effective date of the CFPB’s TILA-RESPA Integrated Disclosures (TRID) regulation.
“We share the Bureau’s goal that these new disclosures help consumers better understand their terms when they buy a home or refinance their mortgage,” the letter states. “Stakeholders are rewriting business processes, upgrading software and training staff to comply with the 1,888-page regulation. Unfortunately, stakeholders are not able to test the processes used to develop these new disclosures in real-life transactions before the implementation date. And, covered loans originated prior to October 3rd will need to follow the old rules and forms through loan closing, which creates an environment ripe for human errors. We know from implementing past regulations that unforeseen issues will arise in actual transactions. Therefore, a formal hold-harmless period through December 31 will allow stakeholders to make a good-faith effort to comply with the TRID regulation without the fear of potential enforcement actions or lawsuits.
“A hold-harmless period allows the Bureau to work with industry to gather data about implementation and provide written guidance to address common industry implementation hurdles that emerge between now and the end of the year,” the letter continues. “Without more clarity, the result is likely to leave homebuyers with less flexibility to buy and close on a home on their terms and potentially fewer companies to work with.”
In addition to NAFCU and CUNA, the letter is signed by the ABA, American Escrow Association, American Land Title Association, Appraisal Institute, The Appraisal Firm Coalition, Collateral Risk Network Community Home Lenders Association, Consumer Bankers Association, Consumer Mortgage Coalition, Community Mortgage Lenders of America, Independent Community Bankers of America, Mortgage Bankers Association, National Association of Home Builders, National Association of Mortgage Brokers, National Association of Realtors, Real Estate Services Providers Council, Inc., and the Real Estate Valuation Advocacy Association.