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CUNA, FI Trades Ask FFIEC to Better Articulate Policies on TRID
Thursday, September 10, 2015 6:45 AM

Credit Union National Association and other financial trade associations joined forces Friday to underscore the urgent need of formal regulatory guidance regarding the new TILA/RESPA Integrated Disclosure (TRID) rule that goes into effect Oct. 3. Without it, their letter warns, the "fear of enforcement actions for errors committed while acting in good faith will severely constrain consumer access to needed mortgage credit." 

In June, CFPB Director Richard Corday announced his agency would grant mortgage lenders leniency on the TRID implementation date. However, the letter urges the Federal Financial Institutions Examination Council (FFIEC) to articulate "precise policies for examining and supervising financial institutions for the initial months after the TRID implementation date."

CUNA and partners also ask the FFIEC to:

  • Provide a clear transition period that addresses how regulators will oversee and examine regulated institutions for TRID compliance during this transition period; and
  • Establish predictable regulatory restraint by enunciating clear guidelines that, if met in good faith, would afford institutions with enforcement and examination relief for a reasonable time period following Oct. 3.  

The FFIEC is comprised by the heads of the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Consumer Financial Protection Bureau, the National Credit Union Administration, the Office of the Comptroller of the Currency, and a state financial regulatory bureau.