Joint Trades letter of Support to Pearce Sherman

May 5, 2015


The Honorable Steve Pearce                                                       The Honorable Brad Sherman

United States Representative                                                   United States Representative

2432 Rayburn House Office Building                                         2242 Rayburn House Office Building

Washington, DC 20515                                                                   Washington, DC 20515


Dear Representatives Pearce and Sherman: 


The undersigned organizations thank you for introducing H.R. 2213, which will provide a reasonable hold-harmless period through the end of the year following the August 1 effective date of the Consumer Financial Protection Bureau’s TILA-RESPA Integrated Disclosures (TRID) regulation. 


We share the Bureau’s goal that these new disclosures help consumers better understand their terms when they buy a home or refinance their mortgage. Stakeholders are rewriting business processes, upgrading software and training staff to comply with the 1,888-page regulation. Unfortunately, stakeholders are not able to test the processes used to develop these new disclosures in real-life transactions before the implementation date.  And, covered loans originated prior to August 1st   will need to follow the old rules and forms through loan closing, which creates an environment ripe for human errors. We know from implementing past regulations that unforeseen issues will arise in actual transactions. Therefore, a formal hold-harmless period through December 31 will allow stakeholders to make a good-faith effort to comply with the TRID regulation without the fear of potential enforcement actions or lawsuits. 


A hold-harmless period allows the Bureau to work with industry to gather data about implementation and provide written guidance to address common industry implementation hurdles that emerge between now and the end of the year. Without more clarity, the result is likely to leave homebuyers with less flexibility to buy and close on a home on their terms and potentially fewer companies to work with. 




American Bankers Association

American Escrow Association

American Land Title Association Appraisal Institute 

Community Home Lenders Association 

Consumer Bankers Association

Consumer Mortgage Coalition

Community Mortgage Lenders of America

Credit Union National Association

Housing Policy Council of the Financial Services Roundtable

Independent Community Bankers of America

Mortgage Bankers Association

National Association of Federal Credit Unions

National Association of Home Builders National Association of Realtors Real Estate Services Providers Council, Inc.