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From Banking and Finance Law Daily, October 2, 2015

CFPB informs mortgage industry of TRID compliance expectations

By John M. Pachkowski, J.D.

With the Oct. 3, 2015, effective date of the Consumer Financial Protection Bureau’s Know Before You Owe mortgage disclosure rule (or TRID rule) imminent, the bureau sent a letter to mortgage industry trade groups setting forth the CFPB’s compliance expectations.

In a statement released on Oct. 2, 2015, the CFPB noted, “During initial examinations for compliance with the rule, the Bureau’s examiners will evaluate an institution’s compliance management system and overall efforts to come into compliance, recognizing the scope and scale of changes necessary for each supervised institution to achieve effective compliance.”

The bureau’s statement continued, “Examiners will expect supervised entities to make good faith efforts to comply with the rule’s requirements in a timely manner.”

Specifically, examiners will consider an institution’s:

  • implementation plan, including actions taken to update policies, procedures, and processes;

  • training of appropriate staff; and

  • handling of early technical problems or other implementation challenges.

The CFPB noted that this is similar to the approach it took in initial examinations for compliance with the mortgage rules that became effective at the beginning of January 2014.

It should be noted that the Office of the Comptroller of the Currency also sent a letter to the American Bankers Association outlining the OCC’s initial compliance expectations that are similar to the expectations highlighted in the CFPB’s statement.

Companies: American Bankers Association

MainStory: TopStory CFPB Mortgages RESPA TruthInLending

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