A Regulatory & Legislative Advisory for Compliance Professionals
Inside . . .
2 Further Study
Needed on QM/QRM
3 ABA: Put Supreme
Bank Secrecy Act
5 Revised Guidance,
FAQs on Iran JCPOA
5 Enhanced Cash
California and Texas
6 FinCEN: No FBME
Access to US Banking
6 Mastercard to
7 ATM Skimming Up
ABA RENEWS CALL FOR TRID TRANSITION PERIOD
The Federal Financial Institutions Examination Council should “formally establish a
transition period” in anticipation of the new TILA-RESPA integrated disclosures taking
effect October 3, ABA said in an August 12 letter to top financial regulators. The
association asked that the FFIEC issue formal guidance articulating how its agencies
will examine and supervise mortgage originators in the months after TRID takes effect.
The transition period “would provide needed certainty to the credit markets and
encourage lenders to continue to provide mortgage credit to qualified borrowers,” ABA
said, adding that “the only way to realistically ensure an orderly transition is to confirm
that supervisory standards work in tandem with lender efforts to refine and debug
systems following the effective date.”
“While fine-tuning by the vendors is necessary for lenders to comply with the new
rules, many lenders have yet to receive operational systems,” ABA added, noting that
a transition period would accommodate the need for banks to adjust to vendor delays,
changes and testing, as well as debugging systems after delivery and training staff.
Read the letter.
TRID Compliance Resources Updated
In other TRID-related news, the Consumer Financial Protection Bureau on August 6
issued revised compliance guides and lender resources for the TRID disclosures.
Resources include a compliance guide, guide to forms, closing factsheet, disclosure
timeline, integrated loan disclosure forms and sample, webinars, supervision and
exam materials, and more. Read more.
CFPB Releases Index to TRID Compliance Questions
The agency has also released an index of the questions and answers from its five
TRID-related webinars to help answer bankers’ compliance questions about the TRID
disclosures. Full recordings of the webinars are also available online, and each
webinar recording now includes a clickable table of contents that allows the viewer to
jump directly to the appropriate portion of the recording. The questions cover preapplication activities, the definition of “application,” the TRID rule’s scope, record
retention, variations and tolerances, redisclosures, details on the Loan Estimate and
Closing Disclosure forms and the required settlement booklet. View the index.
CFPB Releases Spanish Version of TILA-RESPA Form Guide
Separately, the CFPB has also released the Spanish version of Your Home Loan
Toolkit, intended to help consumers understand the new Loan Estimate and Closing
Disclosure forms that lenders are required to begin providing in October. Creditors
must distribute the toolkit to mortgage applicants as part of the loan application