Sixteen industry trade groups, including the American Bankers Association, the Mortgage Bankers Association, and Financial Services Roundtable, have sent a letter to Director Cordray in which they requested that the CFPB provide additional guidance to help the mortgage industry implement the new TILA-RESPA Integrated Disclosures Rule that will become effective on August 1, 2015.

In the letter, the trade groups asked the CFPB to provide clear written authoritative guidance in addition to offering oral guidance through webinars and other venues.  The trade groups expressed their belief that due to the complexity of the rule, the CFPB should memorialize its guidance on issues to ensure a timely and effective implementation.

In the letter, the trade groups said, “Uniform written guidance developed with stakeholders’ input that can be relied upon will further fair competition and minimize the possibility of undue liability increasing costs.  Most importantly, it will ensure that consumers will not be harmed by unnecessary confusion.”

In order to successfully put the new law into effect, the trade groups also recommend that the CFPB:

  • Continue to actively participate in conferences and forums
  • Provide additional exemplar forms
  • Maintain contact with industry vendors
  • Resolve conflicting regulations

We have extensively covered the CFPB and Federal Reserve Board’s  June and August webinars that have addressed questions about the final TILA-RESPA Integrated Disclosures Rule.  The recommendations of the trade groups echo concerns we have heard from industry members, and we consider the concerns to be valid.