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CFPB Fails to Comply with Congressional Review Act Moving TRID date to Oct. 3rd

Date 06-18-2015

CourthouseIn a statement made June 17th, the Consumer Financial Protection Bureau (CFPB) announced a proposal to delay implementation of the TILA-RESPA Integrated Disclosures (TRID) rule until Oct. 1st. The CFPB’s original implementation date of Aug. 1st had been been pushed to Oct. 1st, as they claim an “administrative error” caused the delay of Know Before You Owe rule. On June 24, 2015, the Bureau announced in a new Press Release, the selection of Saturday, October 3, 2015, rather than October 1, 2015, as the proposed implementation date. 

Under the Congressional Review Act, the CFPB failed to timely notify Congress, which requires agencies to submit the rule to Congress and the Government Accountability Office 60 days before the effective date. The agency’s submission should include (1) a copy of the rule; (2) a concise general statement relating to the rule, including whether it is a major rule; and (3) the proposed effective date of the rule.

According to CFPB Director Richard Cordray, the bureau “made this decision to correct an administrative error that we just discovered in meeting the requirements under federal law, which would have delayed the effective date of the rule by two weeks. We further believe that the additional time included in the proposed effective date would better accommodate the interests of the many consumers and providers whose families will be busy with the transition to the new school year at that time.”

At Khani & Auerbach, we were already well on our way to being prepared to implement these new procedures into our real estate practice, however, the CFPB’s decision to delay the deadline for their implementation is great news for everyone. The consumers, the vendors and the industry in general are all not exactly “ready” and there are aspects of TRID that simply made no sense, further confusing the consumer. This push to Oct. 3rdst was definitely something we expected and comes as no surprise. The CFPB listened to the industry and its concern for consumers.

With that said, Khani & Auerbach highly recommends that you initiate your real estate transactions before the implementation date expected for October 1st.

Call the attorneys at Khani & Auerbach (954) 921-1517 if you have any questions about this or any real estate matters.