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#2021135 - 06/18/15 01:27 PM Re: Effective Date Delayed trying_to_comply
Red Raiders Offline
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I feel your pain Lilly2pet!! smile
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TRID - TILA/RESPA Integrated Disclosures Rule
#2021141 - 06/18/15 01:35 PM Re: Effective Date Delayed trying_to_comply
Skittles Online
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Lilly - back when CIP was first enacted it got down to almost DDay - a matter of a week or less (if my memory is correct); and then it was delayed a year. Of course that was long before the CFPB, etc.
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#2021145 - 06/18/15 01:39 PM Re: Effective Date Delayed trying_to_comply
John Burnett Offline
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CIP, in retrospect, was a cakewalk compared to TRID. It's like comparing crossing a rural street with hiking the Appalachian Trail.

But could you be remembering a delay involving the Regulation GG rules, Skittles? Our memory is that the CIP rules had a fairly generous implementation period, with an effective date of October 1, 2003, that wasn't postponed.
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#2021155 - 06/18/15 01:52 PM Re: Effective Date Delayed trying_to_comply
RR Joker Offline
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I just assumed they miscalculated time from FR publication to start based on law.
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#2021177 - 06/18/15 02:19 PM Re: Effective Date Delayed trying_to_comply
ComplianceNerd Offline
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Happy Birthday to ME from the CFPB! Yesterday was my birthday and I couldn't think of a better gift. (Well maybe redacting the whole darn thing but that's wishful thinking.)
Let's hope this sticks!
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#2021182 - 06/18/15 02:28 PM Re: Effective Date Delayed trying_to_comply
MarieR Offline
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A vendor sent this:

The CFPB failed to timely notify Congress under the Congressional Review Act, which requires agencies to submit the rule to Congress and the Government Accountability Office 60 days before the effective date. The agency's submission should include (1) a copy of the rule; (2) a concise general statement relating to the rule, including whether it is a major rule; and (3) the proposed effective date of the rule
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#2021194 - 06/18/15 02:46 PM Re: Effective Date Delayed John Burnett
raitchjay Online
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Originally Posted By John Burnett
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.


I didn't get that reference either.....

a) We must simplify this current 'backward' system we have that the consumer can't understand

b) We must shield families enjoying their summer from this simplified fix

Hmm.
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#2021200 - 06/18/15 02:54 PM Re: Effective Date Delayed trying_to_comply
TryingtoComply Offline
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Thankful for the extension; however, I have concerns about the CFPB and their reasoning. They sound like a bunch of idiots to me.

Just had to say that publicly. Feel better now!
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#2021203 - 06/18/15 02:55 PM Re: Effective Date Delayed trying_to_comply
RR Becca Offline
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out of the frying pan...
I'm just grateful for the (proposed) additional testing and training time. You won't find me looking this particular gift horse in the mouth. smile
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#2021208 - 06/18/15 03:09 PM Re: Effective Date Delayed trying_to_comply
RR Joker Offline
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I didn't think that comment was all that bizarre...we've been screaming that this was the busiest time of year with new home purchases, school and vacations all going on.

I don't think that's their real reason, however...they just needed a 'feel good' statement other than just 'we screwed up'.
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#2021210 - 06/18/15 03:15 PM Re: Effective Date Delayed trying_to_comply
raitchjay Online
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Yes, but WE are compliance people....and the CFPB isn't saying (i don't think) the reason for the delay is because it's busy for us.....busy consumers aren't going to be bothered because they're looking (or really, not looking) at an LE instead of a GFE.
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#2021213 - 06/18/15 03:23 PM Re: Effective Date Delayed trying_to_comply
Kathleen O. Blanchard Offline

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But you are providers. And providers were referenced.
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#2021219 - 06/18/15 03:32 PM Re: Effective Date Delayed trying_to_comply
raitchjay Online
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Oh yes, we were...just re-read it. Ok.
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#2021226 - 06/18/15 03:43 PM Re: Effective Date Delayed trying_to_comply
Kathleen O. Blanchard Offline

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I read it several times to figure it out!
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#2021249 - 06/18/15 04:55 PM Re: Effective Date Delayed trying_to_comply
Kelcey D Offline
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I'm grateful for the extra time... but, at the same time I'm annoyed that they can make an "administrative error" and be able to move things around, yet if we were to make an error on their rule, we'd be subject to enforcement actions and hefty fines. Also, the line about families getting ready for the school year is maddening because that has long been an argument which has been seemingly ignored until it served them.

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#2021252 - 06/18/15 05:00 PM Re: Effective Date Delayed trying_to_comply
Sage Offline
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I guess there was a "changed circumstance"...

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#2021259 - 06/18/15 05:18 PM Re: Effective Date Delayed trying_to_comply
Luv2run Offline
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^^^^^^LIKE
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#2021267 - 06/18/15 05:45 PM Re: Effective Date Delayed trying_to_comply
RR Joker Offline
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Good one!
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#2021269 - 06/18/15 05:51 PM Re: Effective Date Delayed Sage
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Originally Posted By Sage
I guess there was a "changed circumstance"...



++++++ 1,000,000,000,000,000
Quote of the year!

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#2021271 - 06/18/15 05:51 PM Re: Effective Date Delayed trying_to_comply
trout22 Offline
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I'm just not excited about the fact that the 'new' effective date will be on a Thursday. I was looking forward to having a weekend as a buffer; mid-week will cause more of a mess. Maybe they'll push back to 11/1 instead which will put it on a Sunday (fingers crossed!).

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#2021273 - 06/18/15 05:56 PM Re: Effective Date Delayed trying_to_comply
Kathleen O. Blanchard Offline

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But then everyone will say it is right in between Halloween and Thanksgiving.

There just is never a good time.
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#2021280 - 06/18/15 06:24 PM Re: Effective Date Delayed trying_to_comply
raitchjay Online
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The day after i retire would be a good time. wink
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#2021282 - 06/18/15 06:27 PM Re: Effective Date Delayed trying_to_comply
Truffle Royale Offline

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I foresee the problem being the fact that management and employees alike will say 'well, don't have to worry about that now. Let's turn our attention to (inset a project.) That leaves me sounding like the little boy who cried wolf.

This whole thing just confirms that Cordray and the CFPB have no freakin' clue. They just have the superman suit to wear in front of the consumers they're saving from the big bad banks.

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#2021283 - 06/18/15 06:29 PM Re: Effective Date Delayed Sage
RobinB Offline
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Originally Posted By Sage
I guess there was a "changed circumstance"...



Love it!

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#2021284 - 06/18/15 06:30 PM Re: Effective Date Delayed trying_to_comply
RobinB Offline
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