June 3, 2015
The Community Bankers Association of Illinois urges the Consumer Financial Protection Bureau to increase the likelihood of a successful implementation of the TILA-RESPA Integrated Disclosure (TRID) by allowing for a period of restrained enforcement and liability (a grace period) for community banks attempting to comply in good faith with the new regulations between the August 1st effective date through year-end 2015.
Given the complex nature of integrating the forms and a lack of live testing, unintended consequences can undoubtedly be expected which will complicate the home purchase and residential mortgage finance process. In addition, a period of restraint, when combined with a good faith attempt to comply, is not without precedent. CBAI believes the use of a grace period in implementing the TRID is necessary and will be beneficial to consumers and community banks. Read Letter.