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CFPB Announces Leniency for Good Faith Efforts to Comply as to TRID Implementation, But No Formal Grace Period

In response to a letter from numerous Senators, and in response to “considerable input” from other members of Congress and various trade groups, the Consumer Financial Protection Bureau today announced that it will employ leniency in relation to implementation of the TILA-RESPA Integrated Disclosure Rule.

The CFPB’s letter states that the CFPB “will be sensitive to the progress made by those entities that have squarely focused on making good-faith efforts to come into compliance with the Rule on time,” and that the approach “is consistent with the approach we took to implementation of the Title XN mortgage rules in the early months after the effective dates in January 2014.”

However, the letter stops short of providing a formal grace period, “hold harmless” period, or stay of enforcement.

More specifically, the letter states:

“I have spoken with our fellow regulators to clarify that our oversight of the implementation of the Rule will be sensitive to the progress made by those entities that have squarely focused on making good-faith efforts to come into compliance with the Rule on time. My statement here of this approach is intended to ease some of the concerns we have heard about this transition to new processes in the coming months and is consistent with the approach we took to implementation of the Title XN mortgage rules in the early months after the effective dates in January 2014, which has worked out well.”

As you may recall, the CFPB stated in its “Supervisory Highlights” report for Winter of 2015 that “[m]ost of the Title XIV rules took effect in January 2014 and the CFPB commenced supervisory examinations for compliance four months after the effective date.” Our update as to the CFPB’s “Supervisory Highlights (Winter 2015)” report is available here:  Link to Prior Update.

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Patrick Kane practices in Maurice Wutscher’s commercial litigation, consumer credit litigation, insurance recovery and advisory, intellectual property litigation, and equine law practice groups. Patrick has substantial experience in a variety of civil matters including business litigation, insurance recovery, foreclosure litigation, wrongful death, product liability, general tort litigation and general liability defense. Among other achievements, he has served as first chair in a five-day jury trial and as second chair during a weeklong arbitration. In 2012, the San Diego Daily Transcript named him a “Young Attorney of the Year.” Patrick's equine practice focuses on the representation of industry participants at administrative hearing and appeals, purchase and sale agreements, partnership and limited liability creation, gaming law, regulatory matters, and equine related negligence actions. In 2015, he was appointed to serve the California Horse Racing Board as a hearing officer. Patrick graduated from the University of San Diego School of Law. He obtained his undergraduate degree from the University of Arizona where he majored in Animal Science and was a graduate of the Race Track Industry Program; there he received the Mildred Vessels Scholarship Award and the Race Track Industry Program’s Scholarship Award.

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