On July 7, 2015 the MCUL submitted comments to the CFPB addressing its proposal to delay the effective date of the TILA/RESPA Integrated Mortgage Disclosure (TRID) rule encouraging the CFPB to delay the effective date. On July 21st the CFPB issued a final rule with technical amendments delaying the mandatory effective date to October 3, 2015.
The final rule includes technical corrections to two provisions of the TRID rule with both changes affecting amounts on the closing disclosure addressing cash required at closing and amounts credited by the lender.
In our letter the MCUL, as well as many other commenters, expressed the need for a formal grace period. The MCUL has also received numerous questions on whether or not a credit union, if ready to implement the new disclosures prior to the effective date, could begin using the disclosures. In the final rule the CFPB rejected the requests for a formal grace period or a dual compliance period, meaning early compliance with the rule is prohibited.