ALTA Urges Regulators to Provide Guidance on TRID Enforcement
September 17, 2015
ALTA joined 17 other industry groups urging federal regulators to provide formal guidance on how regulators plan to enforce the TILA-RESPA Integrated Disclosure (TRID) rule for the initial months following implementation on Oct. 3.
The letter asks the Federal Financial Institutions Examination Council (FFIEC) “to implement a clearly articulated transition period that addresses how regulators will oversee and examine regulated institutions for TRID compliance during this transition period.”
Without clear guidance, it’s expected access to mortgage credit will be constrained due to fear of enforcement actions for errors committed in good faith. The Consumer Financial Protection Bureau has said it will be sensitive to those making good-faith efforts to comply.
“Transitioning to the new TRID regulatory framework is a sea change for every participant in the mortgage lending,” the letter stated. “Industry stakeholders have undertaken extensive efforts to comply with these rules, but, even now, they are discovering significant compliance issues. These discoveries raise liability concerns that cannot be realistically resolved before the October 3 deadline, as many will require formal authoritative guidance.”
The letter also asked the FFIEC to recognize the severe penalties that can arise under these new rules. Because of this, the groups asked that the FFIEC announce guidelines that would provide institutions making a good-faith effort to comply relief from enforcement for a reasonable period following Oct. 3.
Joining ALTA on the letter were American Bankers Association, American Escrow Association, The Appraisal Firm Coalition, Appraisal Institute, Collateral Risk Network, Consumer Bankers Association, Community Home Lenders Association, Consumer Mortgage Coalition, Community Mortgage Lenders, Credit Union National Association, Housing Policy Council, Independent Community Bankers of America, Mortgage Bankers Association, National Association of Home Builders, National Association of Mortgage Brokers, National Association of Realtors and Real Estate Services Providers Council.
ALTA has urged Congress to pass legislation that would provide a hold-harmless period following TRID implementation. ALTA also has asked the CFPB to announce a hold-harmless period to help provide clarity on how to comply.
Contact ALTA at 202-296-3671 or [email protected].