SPECULATION ABOUT THE CFPB’S PENDING TRID PROPOSAL

As a result of a lot of pressure from many players in the mortgage lending game the CFPB has reluctantly agreed to publish proposed rules to clarify the massive pile of confusion that is called TRID. Recently CFPB Director Cordray sent a letter to the leadership and members of several industry trade groups reporting that the agency has begun drafting a Notice of Proposed Rulemaking on the TRID rules. Cordray stated the goal for publication is late July.

Content – Although the content of the proposal is not yet known, the Director suggested it would likely incorporate some of the Bureau’s informal guidance into the regulatory text and commentary “where adjustments would be useful for greater certainty and clarity.” We suspect that much of the clarification will come from a series of webinars conducted by CFPB staff over the past year.

Dates – The CFPB has promised to “fast track” the clarification. They have already been working on the revisions for more than a year. If proposed regulations are published on a fast track in late July we expect at least a 60- to 90-day comment period. Then the CFPB would need at least 3- to 6-months to digest the comments and draft final rules. If a final rule is published in the Spring 2017 we expect an immediate effective date, with a mandatory compliance date of 6- to12-months to allow time for the loan origination software (LOS) vendors to program the changes. That puts us out to Fall of 2017 or Spring 2018. The LOS vendors will likely miss another deadline, then the CFPB will provide a further delay so families can enjoy Trick or Treating or Spring Break. So maybe the clarification that is needed right now is finally in place by the end of 2018.

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