Cordray Signals ‘Hold-Harmless’ Period for TRID Compliance

Testifying before the House Financial Services Committee today, Consumer Financial Protection Bureau Director Richard Cordray signaled that the bureau and other financial regulators are working on guidance for a formal ‘hold-harmless’ period to facilitate compliance after the TILA-RESPA integrated disclosures take effect on Saturday.

“I’m pushing hard for it to happen before Oct. 3,” Cordray said in response to questions from Rep. Brad Sherman (D-Calif.), a sponsor of ABA-backed legislation to provide a grace period for TRID compliance. “I’d hoped that it would happen before today. It is going to happen.”

Cordray added that “there will be time for [financial institutions] to work to get it right and not have to be perfect on the first day,” adding that the regulators’ approach to TRID in the early months “will be diagnostic, not punitive.” ABA has strongly advocated for clear, written guidance from the regulators on how they will examine and enforce TRID compliance.

In related news, ABA sent a memo to all member bank CEOs earlier today to provide an update on TRID implementation and options bankers may be considering. The memo addresses the late software deliveries being reported across the industry, leaving little to no time for testing and training, and the regulatory and legal environment around TRID implementation.