The CFPB has issued its formal proposal to delay the effective date of the TILA-RESPA Integrated Disclosures (TRID) rule until Saturday, October 3, 2015.  The new effective date comes only a week after the CFPB announced it would delay the effective date until October 1, 2015 due to an administrative error that was made in the rules disclosure and review process.  Specifically, under the Congressional Review Act, Congress and the Government Accountability Office must receive any new rule at least 60 days prior to the rule taking effect.  However, the CFPB failed to submit its notice until after the 60 day deadline had passed and was forced to delay the effective date of the TRID rule as a result.

Although based on when the CFPB completed the required filing, the effective date of the TRID rule would have been delayed until August 15, 2015, the CFPB decided to propose a longer delay.  In the CFPB’s press release, the agency says it believes pushing back the effective date to the first Saturday of October “may facilitate implementation by giving industry time over the weekend to launch new systems configurations and to test systems.”  The Saturday launch date is also consistent with original industry plans to transition to the new TRID rule on Saturday, August 1, 2015.  According to the CFPB, “moving the effective date may benefit both industry and consumers with a smoother transition to the new rules.”  As we noted previously, concerns with the finalization of the necessary software to comply with the TRID rule may have been a factor in the CFPB’s decision.

The proposal will be published in the Federal Register on June 26, and comments are due by July 7.

The CFPB has issued a final rule delaying the effective date of  the remittance transfer rule pending finalization of its December 2012 proposal to make changes in three areas.  The effective date had been set for February 7, 2013.  In addition to the substantive changes, the CFPB had proposed to delay the effective date until 90 days after the changes are finalized. Comments on the proposed delay were due by January 15 and comments on the substantive changes are due by January 30.  

In October 2012, the CFPB released a safe harbor list of countries that qualify for an exception in the remittance rule that allows estimated disclosures of certain amounts instead of the disclosure of an exact amount where the laws of the recipient country do not permit a determination of the exact amount. When the list was released, the CFPB indicated that it would not remove countries from the list before May 1, 2013.  In the final rule delaying the remittance rule’s effective date, the CFPB indicated that it would reassess the earliest date on which countries may be removed from the list in connection with finalization of the December 2012 proposal but that date will not be sooner than May 1, 2013.