TRID Hold Harmless HR 3192 - July 27

July 27, 2015


The Honorable Jeb Hensarling                                                    The Honorable Maxine Waters

Chairman                                                                                             Ranking Member

House Financial Services Committee                                       House Financial Services Committee

2149 Rayburn House Office Building                                        B301C Rayburn House Office Building

Washington, D.C. 20515                                                                Washington, D.C. 20515


Dear Chairman Hensarling and Ranking Member Waters:

The undersigned organizations urge you to pass H.R. 3192, the Homebuyers Assistance Act, which will provide a reasonable hold- harmless period for enforcement of the of the Consumer Financial Protection Bureau’s TILA-RESPA Integrated Disclosures (TRID) regulation for those that make good- faith efforts to comply. A hold- harmless period helps ensure consumers’ real estate closings will not be disrupted after this complicated regulation’s October 3 effective date. We note that 250 Members of the House and 41 Senators have written to CFPB urging the action that this legislation would mandate.


We appreciate that the Bureau indicated it will be sensitive to the progress made by those entities that make good-faith efforts to comply. At the same time, industry needs more certainty that their good- faith efforts to comply while still meeting consumers’ expectations does not expose lenders and settlement service providers to litigation during the initial period after the regulation becomes effective. This certainty will reduce the likelihood that consumers will experience delays or disruptions in the months following the October 3 implementation date.


We appreciate that the Bureau shares our goal for a smooth and successful implementation of the regulation. While the industry has been granted time to prepare for this new disclosure regime, there is no transition period for the regulation. 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 after these new disclosures are put into use.





American Bankers Association

American Bankers Insurance Association

American Escrow Association

American Land Title Association

Appraisal Institute

Appraisal Firm Coalition

Collateral Risk Network

Community Home Lenders Association

Community Mortgage Lenders of America

Consumer Mortgage Coalition

Consumer Bankers Association

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 Mortgage Brokers

National Association of Realtors®

Real Estate Services Providers Council, Inc.

Real Estate Valuation Advocacy Association


cc:          Rep. French Hill Rep. Brad Sherman