http://www.consumerfinance.gov/newsroom/...isclosure-rule/

JUN 17 2015
Statement by CFPB Director Richard Cordray on Know Before You Owe Mortgage Disclosure Rule
WASHINGTON, D.C. — Today, Consumer Financial Protection Bureau (CFPB) Director Richard Cordray issued the following statement on the Know Before You Owe mortgage disclosure rule:

“The CFPB will be issuing a proposed amendment to delay the effective date of the Know Before You Owe rule until October 1, 2015. We made this decision to correct an administrative error that we just discovered in meeting the requirements under federal law, which would have delayed the effective date of the rule by two weeks. We further believe that the additional time included in the proposed effective date would better accommodate the interests of the many consumers and providers whose families will be busy with the transition to the new school year at that time.”

The public will have an opportunity to comment on this proposal and a final decision is expected shortly thereafter.

We'll have to see when the proposal comes out and how long the comment period will be. We'll then have to see how quickly they come out with a final rule.

I encourage EVERYONE to submit a comment requesting the effective date be dalyed until at least January 1.

Fixed.

Why are they even wasting time with a proposal? Who in their right mind is going to comment in favor of the August 1st date?

I foresee a comment period ending July 31.

(This is simply conjecture, I know of no actual comment period dates )

I think they will declare an emergency under the APA and shorten the normal timeframes for comment and finalization. If people don't know well in advance if a delay will really be implemented, nothing is accomplished by proposing one.

I thought the announcement was a joke. Is this for real?

It is real. We just don't have as many details as we would like.

Director Cordray has stated that an administrative error under federal law would require a pushback of two weeks. Rather than merely push back to August 15, however, the CFPB is going to issue a proposal to push back to 10/1. Their reasoning for it is a bit bizarre, but the blood pressure of compliance people would certainly benefit from having more time to train and test. I think if CFPB had announced a possible delay before now, software vendors would have been dragging their feet even more than they have been. I find it mind blowing that many lenders have not been able to do testing yet after CFPB provided such a long time between when the rule was issued and the original effective date.

For those who want to understand the process and the strictures, go here:

https://www.federalregister.gov/uploads/2011/01/the_rulemaking_process.pdf

I agree re the vendors.

Has anyone found a link for comments yet?

They did not publish the proposal yet, once they do, then you can comment.

Ah. That would be why I can't find anything except the article linked above, huh?

I wonder who finally got through to them? Regardless, thank goodness!

<--- still no LOS updates for testing.

I am glad to hear this. We are going through a conversion, and won't have new software to even test until the last week of July. A little bit of breathing room.

Is there any likelihood that they will let us begin using the new forms Aug 1 anyways... just to get used to the process? I'm guessing no, but keeping my fingers crossed. I was ready to check this project off of my list. :-)

yeah, my OCDness will likely have a problem dealing with this delay when my entire being is focused on 8-1-15 right now.

I honestly thought I'd lose it the last time we went through final, final proposal to the final, final stuff last time.

Is this incompetence or what?

Any idea what this "administrative error" was? Smoke and mirrors?

My solution to this? Today is April 18th!

I wonder whether the proposal to delay will unveil the administrative glitch the Bureau made. As for the two-month delay, while I agree that it will give the industry and systems providers some breathing room, the suggestion that it will help families who are caught up in the "back to school" season is just plain bizarre.

Full Disclosure: I need to vent.

Now? They are now, a mere 43 days from 8/1, considering a delay? What is wrong with these bureaucrats?? They've been ignoring our pleas and comments for months and now, 43 days from DDay they decide to consider a delay. It's official; no doubt in my mind they are all idiots and truly do not understand the industry they have been tasked with regulating.
I'm grateful for the extra time, don't misunderstand me. It's just they could have been a bit more 'engaged' with the process and realized that what everyone has been asking/pleading for should have come sooner than 43 days prior. Thank you. Rant over.

Does anyone know what this 'glitch' is?

Who cares! If this is what they need to feel all warm and fuzzy from backing down a bit, let 'em have it.

Just look at it like they are a big exec at your bank who spouts off on about something on and on about something they have no clue about, and they just realized how stupid they sound and look... let them back away quietly and gracefully and take the gimme!