Yesterday, the CFPB issued a statement regarding enforcement of the new TRID rule. The statement is in response to a Congressional request for a grace period through the end of 2015. In its letter, the CFPB stated that it has clarified with other regulators that the CFPB’s oversight regarding TRID implementation “will be sensitive to the progress made by those entities that have squarely focused on making good-faith efforts to come into compliance with the Rule on time.” The letter does not explicitly state that enforcement will be delayed for any length of time, and does not alter the August 1 effective date in any way. The CFPB also issued a fact sheet addressing concerns that the new TRID disclosures will delay closings. The fact sheet explains the three situations which trigger new disclosures and a new three-day waiting period. The fact sheet specifically states that a decrease in the APR will not require a new three-day waiting period if it is based on changes to interest rate or other fees.
For questions regarding the CFPB’s announcement or your TRID implementation plan, please contact Loretta Salzano at (770) 248-2881 or lsalzano@franzen-salzano.com, or Jennifer Dozier at (770) 248-2885 ext. 241 or jdozier@franzen-salzano.com.