The Bureau has a "drop dead date" for finalizing the regulation in January 2013. If it fails to meet that date, the requirements of Title XIV of Dodd-Frank will become effective without the regulation -- something that no one wants to see.
When the final rule is issued, the Bureau may insert a future mandatory compliance date up to a year later.
This was always my understanding too, but then I read this in the proposal and now I'm confused (page 51145 of Federal Register, 3rd column):
"There is no statutory deadline for issuing final rules to integrate the mortgage disclosures under TILA and RESPA, and the Bureau expects that it may take some time to conduct quantitative testing of the forms prior to issuing final rules."
I feel like I must be reading that wrong, but to me it says they don't have to have the final rules for the disclosures issued by January. But, that is inconsistent with everything else I've read so now I have no idea.