19 Trade Associations Urge Passage of TRID Hold-harmless Bill

June 11, 2015

ALTA and 18 other trade associations sent a letter on June 9 urging Congress to pass H.R. 2213, which would provide a reasonable hold-harmless period for enforcement of the of the Consumer Financial Protection Bureau’s TILA-RESPA Integrated Disclosures (TRID) regulation for those that make good-faith efforts to comply.

Introduced by Steve Pearce (R-NM) and Brad Sherman (D-CA), H.R. H.R. 2213 would provide a reasonable hold-harmless period through the end of the year following the Aug. 1 effective date of TRID.

Last week, CFPB Director Richard Cordray indicated the bureau would be sensitive to companies making a good-faith effort to comply with the 1,888 pages of TRID, ALTA had hoped the bureau would announce a specific hold-harmless period.

“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 join trades letter said. “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 August 1 implementation date.”

At least 250 members of the House of Representatives and 41 Senators have written to the CFPB urging action regarding the hold-harmless period.

Cordray said his statement was “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” the CFPB took with enforcement of the Qualified Mortgage and Ability To Repay regulations. Those rules took effect in January 2014, but examiners didn't begin auditing lenders for compliance for four months, according to the bureau's winter 2015 Supervisory Highlights bulletin.

ALTA President Diane Evans NTP met with Director Cordray on May 13 to formally request a hold-harmless period following TRID implementation on August 1. On May 20, ALTA members met with more than 220 members of Congress or their staff to request the hold-harmless period. Additionally, the Title Action Network, ALTA’s 11,000-member advocacy organization, has sent hundreds of emails to members of Congress requesting time for the industry to address possible issues during implementation.

Contact ALTA at 202-296-3671 or communications@alta.org.