Joint Trades Letter to House supporting HR 3192

October 5, 2015


United States House of Representatives Washington, DC 20515


Dear Representative:


On behalf of the undersigned organizations, we urge you to support H.R. 3192, the Homebuyers Assistance Act. This legislation will provide an official hold-harmless period until February 1, 2016, for those making a good-faith effort to comply with the Consumer Financial Protection Bureau’s (CFPB) new TILA-RESPA Integrated Disclosure (TRID) rule, which became effective on October 3, 2015.


We appreciate Representatives French Hill and Brad Sherman for introducing this bipartisan legislation. We note

H.R. 3192 passed the House Financial Services Committee on a strong bipartisan vote of 45 to 13. This legislation recognizes the unavoidable learning curve that accompanies the implementation of any new regulation. This learning curve may be particularly steep for TRID because these new forms and systems have yet to be used in an actual homebuyer transaction. A formal hold-harmless period will help ensure the real estate settlement and mortgage lending industries can adapt their business processes and continue to meet homebuyers’ needs during the first few months following the October 3 implementation.


In his testimony before the House Committee on Financial Services on September 29, CFPB Director Richard Cordray acknowledged that industry will not be perfect on the first day of implementation. Indeed, this view was reinforced by an October 1 letter from the Federal Financial Institutions Examination Council (FFIEC) member agencies, which acknowledged that “additional technical and other questions are likely to be identified once the new forms are used in practice after the effective date.” The letter does not offer a “hold harmless” period, however, and the agencies are unable to protect the industry from the liability risk that will follow during the early days of compliance. The law should recognize this and protect industry from regulatory and civil liability as it makes good faith efforts to comply with the numerous new TRID requirements.


We respectfully request that you vote in favor of the Homebuyers Assistance Act to prevent unnecessary, frustrating, and sometimes costly delays for consumers who buy homes in your communities this fall.




American Bankers Association

American Land Title Association

American Resort Development Association

Appraisal Institute

Arkansas Land Title Association

California Land Title Association

Community Home Lenders Association

Community Mortgage Lenders of America

Consumer Bankers Association

Consumer Mortgage Coalition

Credit Union National Association

Housing Policy Council of Financial Services Roundtable

Independent Bankers Association of Texas

Independent Community Bankers of America

Kentucky Land Title Association

Mortgage Bankers Association

National Association of Federal Credit Unions

National Association of Home Builders

National Association of Mortgage Brokers

National Association of Realtors New York

Land Title Association Ohio Land Title Association

Palmetto Land Title Association

Real Estate Bar Association of Massachusetts

Real Estate Services Providers Council, Inc.

Real Estate Valuation Advocacy Association

The Appraisal Firm Coalition

The Collateral Risk Network

Texas Bankers Association

Texas Land Title Association