Yesterday, June 17, 2015, the US Consumer Financial Protection Bureau ("CFPB") unexpectedly announced that it is publishing a proposal for public comment to postpone the effective date of the TILA-RESPA Integrated Disclosures Rule ("TRID") from August 1, 2015 until October 1, 2015.

In a prepared statement, CFPB Director Richard Cordray indicated that postponing TRID's effective date would correct an "administrative error" the CFPB had "just discovered" in meeting the requirements under federal law.  Somewhat quizzically, Director Cordray tied the delay to the start of the school year stating that the delay would "better accommodate the interests of many consumers and providers whose families will be busy with the transition to the new school year at that time."

It is unclear when the CFPB will publish the proposal but the CFPB indicates that the public will have an opportunity to comment on the proposal with a final decision "expected shortly thereafter."  Given the publication of a proposal, it appears likely that effective date will indeed be delayed.

We will provide updated information on this important proposal and decision as it becomes available.

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