October 1, 2015
As a reminder, this Saturday, October 3, 2015, marks the beginning of TRID. Any person applying for a residential mortgage loan beginning this Saturday must receive the new TRID disclosures.
We understand the next several weeks and months will be stressful as we strive to properly implement these new Federal disclosures.
Please do not hesitate to contact this office if you have any questions or concerns regarding your Credit Union’s implementation plan. On our website, www.bairdlaw.com, there is a TRID Resources page which may answer some of your questions and concerns. As always, we are dedicated to helping Texas Credit Unions implement their mortgage lending programs.
There is some good news from the Consumer Financial Protection Bureau (CFPB).
Richard Cordray, Director of the CFPB, gave a report on Tuesday morning to the House Financial Services Committee. During his report, Cordray re-iterated there would be an informal grace period for several months following the roll-out of TRID.
Cordray stated that any CFPB enforcement actions covering TRID during this grace period would be “diagnostic and not punitive.” Cordray was not specific on how long the grace period would last.
Cordray has promised that a formal grace period announcement will be forthcoming. This grace period should give everyone some breathing room as we all become accustomed to the new mortgage lending environment.
Morton Baird, Karen Miller and Michael Baird