Is it possible for a non-unionized industry to strike? Just curious.

I don't see why not...we've already threatened to approach their front door en masse...I think that would be called 'freedom of speech'. However, we might have to take vacation time to accomplish it!

^^ Sick Leave seems more appropos

That was thrown in to pacify various community groups, IMHO.

True, Romeo!

I hate to be the one to say it, but the CFPB does not have the right or power to combine two laws. Only Congress can pass a new combined law. The CFPB did what they were instructed to do, combined the regulations so that the GFE and early TILA, and HUD 1 and final TILA were combined. Sure it could be better but they accomplished what the FRB and HUD could never get together to do, despite attempts.

Hopefully, overtime glitches and problems in this first go round will be addressed.

But feel free to vent.

Yeah, i definitely blame Congress as much as the CFPB. If simplification is the goal, it's an admirable goal; it's just that what we have is in no way any simpler than what we had.

Some of us remember the results the last time the Fed tried to simplify Reg Z. Things were a little better for a while, but got a lot more complex as the reg struggled to keep up with changes in the way loans are made.

What "get's my goat" on this is the intent of regulation is to create a shopping tool for the consumer free of pressure, all well and good, but then the rule does a 180 by mandating the lender provide near perfection in it's creation of an "estimate" so the borrower can "shop". Am I crazy or isn't this trying to accomplish to divergent goals - shopping and accuracy? Oh and by the way the lender has to be accurate without requiring any information that would help them make it accurate. Bah!

Come now people - venting belongs in the cooler.

Any bets on when the proposal will hit the Federal Register?

Not on this topic, Randy. Given none of our spouses or significant others understand or appreciate what we're going on about here, we need a thread to let it out or we'll burst. And besides, Kathleen gave us permission above.

We're thinking that the October 1, 2003, effective date for the CIP rules wasn't changed. One that did get postponed, in a Federal Register notice published on the initial December 1, 2009, effective date, was Regulation GG. We recall bankers placing virtual bets on whether there would be a delay of that rule, "Prohibition on Funding of Unlawful Internet Gambling."

And KYC which kinda just 'went away' and morphed into CIP...didn't it?

KYC is a concept that was simply not going to gain traction with the American public when it was first proposed. The FDIC was targeted with thousands of adverse comments and the concept went underground, to be exhumed and reinvigorated post-911 in the form of CIP.

This is neither here nor there, but I think during our 60 day delay I'm going to start a band made up of compliance people and call it "Byzantine Flying Spaghetti Monster." Thanks for the laugh, Princess Romeo

Anyone who has been around a while may recall, in the 1990s, when HUD said that business purpose loans secured by residential real estate, including rental properties, were subject to RESPA. There was an uproar in the commercial lending community. Fortunately the lending community won out but it was an exciting time.

We go through this craziness in this industry in cycles.

Since the TRID delay isn't 100% official until after public comment, I'd be curious to know what others are doing since this is still in proposed status.

While we don't want to lose momentum in implementing our new processes for TRID, we also don't want to implement any new processes prior to TRID, that is if it's delayed to 10/1. We have multiple business lines at our bank that have a long list of task items to be completed prior to 8/1 (or now 10/1). The reality is that we'll need to adjust dates for deliverables due to resources, etc.

I'm just curious to know if other banks are moving forward as if the date is 8/1, or if they're adjusting their tasks for the new 10/1 date.

I think the 10/1 will happen but the CFPB must go through the required process of publication and comment, which I expect will be a very short comment period. At the very least it is not possible to go into effect 8/1 because the CFPB missed a notice date that delays implementation for minimum 2 weeks.

I cannot imagine a scenario that it will go into effect prior to 10/1.

Here you are. The proposal is out, for 10/3 - to stay with a Saturday implementation date.

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

Why does it take 23 pages to say they are delaying the date by two months?

Short comment period ends 7/7/15. The extra pages involve updating all the internal references to the 8/1/15 date that are included in the text of the regulation and/or commentary.

I attended the ABA Regulatory Compliance Conference last week, where a delegate from the CFPB had to face town hall questions around the effective date, what did "sensitive" mean from Cordray's letter of a couple weeks ago, etc. I felt bad for the woman fielding all those questions, because the delay was announced the day AFTER the conference ended, the day AFTER she had to defend the CFPB so diplomatically! There would have been a LOT of happy bankers had Cordray just made the announcement a day earlier...

This. And they wonder why we had trouble reading every page of the Reg itself!