Synergy by Association
  • About Synergy
    • Contact Us
    • Board of Directors
    • Synergy Partner Advisory Committee
  • PROGRAM PARTNERS
    • ABA Insurance Services
    • Bank Marketing Center
    • Bankers Alliance
    • Cornerstone Advisors
    • CRA Partners
    • Discover Debit
    • Hagan Hamilton
    • ICBA Securities
    • KeyState Captive Management
    • ODP Business Solutions
    • ServisFirst
    • Shred-it
    • StrategyCorps
    • Vericast
  • ASSOCIATION ALLIANCES
  • PARTNER TOOLKIT
  • About Synergy
    • Contact Us
    • Board of Directors
    • Synergy Partner Advisory Committee
  • PROGRAM PARTNERS
    • ABA Insurance Services
    • Bank Marketing Center
    • Bankers Alliance
    • Cornerstone Advisors
    • CRA Partners
    • Discover Debit
    • Hagan Hamilton
    • ICBA Securities
    • KeyState Captive Management
    • ODP Business Solutions
    • ServisFirst
    • Shred-it
    • StrategyCorps
    • Vericast
  • ASSOCIATION ALLIANCES
  • PARTNER TOOLKIT

Compliance Alliance Question of the Week

5/1/2018

 
Question:
When is the new TRID amendment regarding the black hole issue effective? And can we follow it before the rule is in effect?                                                   
Answer:
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. "
https://files.consumerfinance.gov/f/documents/cfpb_tila-respa_final-rule_amendments-to-federal-mortgage-disclosure-requirements.pdf

Comments are closed.
    Picture

    Archives

    March 2020
    February 2020
    January 2020
    December 2019
    November 2019
    October 2019
    September 2019
    August 2019
    July 2019
    June 2019
    May 2019
    April 2019
    March 2019
    February 2019
    January 2019
    December 2018
    November 2018
    October 2018
    September 2018
    August 2018
    July 2018
    June 2018
    May 2018

    Categories

    All
    Compliance

    RSS Feed

    Compliance Alliance offers a comprehensive suite of compliance management solutions.

    To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.com.
Copyright © 2023 Synergy by Association, Inc.  All Rights Reserved.
1149 Court Street NE  |  PO Box 13429  |  Salem, OR 97309  |  (800) 468-8558
Picture