The federal Consumer Financial Protection Bureau (CFPB) issued its final rule earlier today confirming the delay of the effective date of the TILA-RESPA Integrated Disclosures rule to October 3, 2015.
A copy of the final rule is available at: Link to Final Rule
The final rule also makes certain technical corrections, including:
1. Amending 12 CFR § 1026.38(i)(8)(ii) and (iii)(A) to “include, in the amount disclosed as ‘Final’ for Adjustments and Other Credits, the amount disclosed under § 1026.38(j)(1)(iii) for
certain personal property sales, thus conforming the calculation of Adjustments and Other Credits on the Closing Disclosure and Loan Estimate;” and
2. Amending 12 CFR § 1026.38(j)(1)(iv) to “include, in the amount disclosed as Closing Costs Paid at Closing, lender credits disclosed under § 1026.38(h)(3), thus conforming the disclosure of the borrower’s cash to close in the Calculating Cash to Close and the Summaries of Transactions tables on the Closing Disclosure.”
Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct: (312) 551-9320
Fax: (312) 284-4751
Mobile: (312) 493-0874
Email: rwutscher@MauriceWutscher.com
Admitted to practice law in Illinois
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From: Ralph T. Wutscher [mailto:rwutscher@mauricewutscher.com]
Sent: Thursday, June 25, 2015 11:49 AM
To: Ralph T. Wutscher
Cc: New York Office; Florida Office; New Jersey Office; San Francisco Office; San Diego Office; Philadelphia Office; Ohio Office; Indiana Office; DC Office; Chicago Office
As referenced in our prior update below, the federal Consumer Financial Protection Bureau (CFPB) issued a proposed rule to change the effective date for the “Know Before You Owe” TILA-RESPA Integrated Disclosure rule to October 3, 2015.
A copy of the proposed rule and request for public comment is available at: Click Here
The CFPB previously indicated the effective date would be delayed to Oct. 1, 2015.
The CFPB stated that it “is proposing a new effective date of Saturday, October 3,” explaining that “scheduling the effective date on a Saturday may facilitate implementation by giving industry time over the weekend to launch new systems configurations and to test systems. A Saturday launch is also consistent with existing industry plans tied to the original effective date of Saturday, August 1.”
The proposal will be open for public comment until July 7, 2015.
Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct: (312) 551-9320
Fax: (312) 284-4751
Mobile: (312) 493-0874
Email: rwutscher@MauriceWutscher.com
Admitted to practice law in Illinois
NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.
Our updates are available on the internet, in searchable format, at:
Financial Services Law Updates
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The Consumer Financial Services Blog
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California Finance Law Developments
and
From: Ralph T. Wutscher [mailto:rwutscher@mauricewutscher.com]
Sent: Thursday, June 18, 2015 9:34 AM
To: Ralph T. Wutscher
Cc: New York Office; Florida Office; New Jersey Office; San Francisco Office; San Diego Office; Philadelphia Office; Ohio Office; Indiana Office; DC Office; Chicago Office
Subject: FYI: CFPB to Issue Proposed Amendment Delaying TRID Effective Date to Oct. 1, 2015
The federal Consumer Financial Protection Bureau (CFPB) issued a short press release yesterday, confirming reports that it would be issuing a proposed amendment to delay the effective date for the “Know Before You Owe” TILA-RESPA Integrated Disclosure rule until October 1, 2015.
A copy of the press release is available at: Press Release
The press release simply states:
“The CFPB will be issuing a proposed amendment to delay the effective date of the Know Before You Owe rule until October 1, 2015. We made this decision to correct an administrative error that we just discovered in meeting the requirements under federal law, which would have delayed the effective date of the rule by two weeks. We further believe that the additional time included in the proposed effective date would better accommodate the interests of the many consumers and providers whose families will be busy with the transition to the new school year at that time.
The public will have an opportunity to comment on this proposal and a final decision is expected shortly thereafter.”
Prior to the proposed amendment, the effective date for the “Know Before You Owe” TILA-RESPA Integrated Disclosure rule was August 1, 2015, and would apply to transactions for which the mortgage lender or broker receives an application on or after that date.
Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct: (312) 493-0874
Fax: (312) 284-4751
Email: rwutscher@MauriceWutscher.com
Admitted to practice law in Illinois
NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.
Our updates are available on the internet, in searchable format, at:
Financial Services Legal Developments
and
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