More than 20 real estate industry trade groups joined together Monday in support of HR 3192, the Homebuyer Assistance Act, which will provide an official hold-harmless period for enforcement of TRID for those that make good-faith efforts to comply.
This comes just six days after the Consumer Financial Protection Bureau officially finalized the rule to change the effective date of the Know Before You Owe mortgage disclosure rule, also called the TILA-RESPA Integrated Disclosures rule, to Oct. 3.
The industry welcomed the news after pushing for a delay for some time, but it still wants a more formal grace period on enforcement.
“A hold-harmless period helps ensure consumers’ real estate closings will not be disrupted after this complicated regulation’s Oct. 3 effective date,” the letter, signed by more than a score of groups, read. “We note that 250 Members of the House and 41 Senators have written to CFPB urging the action that this legislation would mandate.”
Currently the CFPB has agreed to an unspecified enforcement grace period, but has left the terms and length of the grace period unclear. This hold-harmless period doesn’t really work, the letter says, as it leaves open too much uncertainty.
“We appreciate that the Bureau indicated it will be sensitive to the progress made by those entities that make good-faith efforts to comply,” the letter states. “At the same time, industry needs more certainty that their good-faith efforts to comply while still meeting consumers’ expectations does not expose lenders and settlement service providers to litigation during the initial period after the regulation becomes effective.
“This certainty will reduce the likelihood that consumers will experience delays or disruptions in the months following the Oct. 3 implementation date,” the letter says. “We appreciate that the Bureau shares our goal for a smooth and successful implementation of the regulation. While the industry has been granted time to prepare for this new disclosure regime, there is no transition period for the regulation. A hold-harmless period allows the Bureau to work with industry to gather data about implementation and provide written guidance to address common industry implementation hurdles that emerge after these new disclosures are put into use.”
The letter was signed by the following organizations:
- American Bankers Association
- American Bankers Insurance Association
- American Escrow Association
- American Land Title Association
- Appraisal Institute
- Appraisal Firm Coalition
- Collateral Risk Network
- Community Home Lenders Association
- Community Mortgage Lenders of America
- Consumer Mortgage Coalition
- Consumer Bankers Association
- Credit Union National Association
- Housing Policy Council of the Financial Services Roundtable
- Independent Community Bankers of America
- Mortgage Bankers Association
- National Association of Federal Credit Unions
- National Association of Home Builders
- National Association of Mortgage Brokers
- National Association of Realtors
- Real Estate Services Providers Council, Inc.
- Real Estate Valuation Advocacy Association