Following NASCUS suggestion, CFPB delays TRID to Oct. 3

JULY 22, 2015 -- Following a recommendation made by NASCUS, the CFPB has pushed back compliance with its TILA-RESPA Integrated Disclosure rules (TRID) to Oct. 3.

In its comment, NASCUS noted that state regulators were concerned about the readiness of small financial institutions to switch to the new integrated disclosure, also known as the “know before you owe” rule. NASCUS told the agency that additional time was necessary to ensure a smooth transition.

The CFPB said it issued the change to correct an administrative error that would have delayed the effective date of the rule by only at least two weeks, until August 15, at the earliest.

“Although many credit unions are prepared to comply with the new rule, the depth and breadth of changes to technology, third-party contracts, and internal policies and procedures presents major challenges for even the most diligent and well-prepared institutions,” wrote Sabrina Bergan, NASCUS Regulatory & Public Policy Counsel. “Given the significant operational and compliance risks involved, NASCUS feels all credit unions could benefit from additional time to train their staff and test their systems,” she stated.

NASCUS also urged the agency to adopt a “safe-harbor” period from legal liability, which would recognize the magnitude of the operational changes that will accompany the rule, and give financial institutions a good-faith opportunity to manage their risk without disrupting their service to members.

CFPB announcement of effective date change

NASCUS comment letter to CFPB

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