October 12, 2015
On October 7, 2015, the U.S. House of Representatives passed HR 3192 to create an official hold harmless period for TRID compliance until February 1, 2016. The bill must now be approved by the U.S. Senate.
This pending legislation reinforces initial leniency implied by the CFPB in their October 1, 2015 letter to industry groups. The CFPB letter states that during their initial examinations of lenders, examiners will review the lender’s “good faith” efforts to comply with the new TRID requirements. The CFPB letter did not specifically create a hold-harmless period for mortgage lenders, which prompted the Congressional effort to formalize initial leniency for TRID violations.
The CFPB letter states:
“During initial examinations for compliance with the rule, the Bureau’s examiners will evaluate an institution’s compliance management system and overall efforts to come into compliance, recognizing the scope and scale of changes necessary for each supervised institution to achieve effective compliance. Examiners will expect supervised entities to make good faith efforts to comply with the rule’s requirements in a timely manner. Specifically, examiners will consider: the institution’s implementation plan, including actions taken to update policies, procedures, and processes; its training of appropriate staff; and, its handling of early technical problems or other implementation challenges.”
Our office is available to help you with any TRID-related issue or concern you may have. Please give us a call if we can help.
All the best,
Morton Baird, Karen Miller and Michael Baird