Will Enforcement be delayed as TILA-RESPA Disclosures Begin?

The House Financial Services Committee (FSC) has scheduled a hearingrn(through its subcommittee on Housing and Insurance) on May 14 titled “TILA-RESPArnIntegrated Disclosure: Examining the Costs and Benefits of Changes to the RealrnEstate Settlement Process.”  The committeernhas not released the names of any witnesses but Barbara Mishkin, writing in thernConsumer Financial Protection Bureau (CFPB) blog maintained by the law firm ofrnBallard & Spahr is making some guesses about the direction the hearing willrntake.</p

New consolidated TILA (Truth-in-Lending Act) and RESPA (Real Estate SettlementrnProcedures Act) disclosures developed by CFPB are slated to go into effect onrnAugust 1 and Mishkin says several FSC members are urging a delay in enforcingrnuse of the forms.   Blaine Luetkemeyer (R-MO), chair of thernsubcommittee holding the hearing, wrote a letter to CFPB Director RichardrnCordray in March urging the agency to adopt a “hold harmless” period ofrnrestrained enforcement until the first of next year and Steve Pearce (R-NM) hasrncosponsored a bill that would provide lenders a temporary safe harbor fromrnenforcement also until January1, 2016.  </p

Mishkin said that Cordray, responded to Luetkemeyer that the January 1, 2016rndate was one of several his agency had considered for implementing the newrndisclosures.  However CFPB receivedrnextensive feedback from lenders that a New Years date had other operational implications</bfor the industry and that August was a better choice given the slowerrnsummertime pace of mortgage applications. rnCordray, however, did not rule out a temporary lenient approach tornenforcement and told Luetkemeyer that CFPB "plans to continue its activernengagement in supporting industry and consumers throughout the implementationrnperiod of the [TRID] Rule." </p