When is the new TRID amendment regarding the black hole issue effective? And can we follow it before the rule is in effect?
The new rule is effective 30 days after publication in the Federal Register which still hasn't happened (as of writing on 04/30/2018). Unfortunately, there’s not an allowance for optional early adoption as there was with the general 2017 TRID amendments which were issued last year:
"The amendments in the final rule will become effective 30 days after publication in the
Federal Register. The Bureau believes the changes should enable industry to implement the
provisions set forth in the TILA-RESPA Rule more cost-effectively and that industry should be
able to implement these changes relatively quickly. Regarding some commenters’ requests for a
later effective date, an optional early compliance period, or an effective date that distinguishes
among transactions based on when a loan application was received, the Bureau declines to adopt
such approaches because the final rule does not impose any new burdens on creditors. Once the
final rule becomes effective, the ability to reset tolerances prior to consummation for a given
transaction will not be limited by when the application was received. The Bureau declines to
make this final rule retroactive, as retroactive rulemaking is disfavored by the courts and the
commenter has not established why it would be appropriate here. "
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