We recently
reported on the TILA-RESPA Integrated Disclosure Rule (TRID),
scheduled to go into effect later this year. On June 9, several
trade groups, including the American Bankers Association and the
Mortgage Bankers Association jointly authored a letter to the House Financial Services
Committee, urging the passage of H.R. 2213, introduced in the House on May 1,
2015, which would "provide a reasonable hold-harmless period
for enforcement of" TRID "for those that make good-faith
efforts to comply." According to H.R. 2213, this
"Enforcement Safe Harbor" would be in place until January
1, 2016.
The Consumer Financial Protection Bureau has already indicated
that it would be "sensitive" to progress made by entities
that make good-faith efforts to comply. However, the trade groups
potentially affected by TRID seek "more certainty" that
their good-faith compliance efforts would protect them from
exposure to litigation, at least for a brief period after TRID
becomes
