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#2021141 - 06/18/15 01:35 PM
Re: Effective Date Delayed
trying_to_comply
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10K Club
Joined: Sep 2002
Posts: 13,965
TN
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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
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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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
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10K Club
Joined: Nov 2002
Posts: 20,656
The Swamp
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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
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Gold Star
Joined: Nov 2011
Posts: 378
Texas ...
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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
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Platinum Poster
Joined: Nov 2005
Posts: 614
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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
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Power Poster
Joined: Oct 2009
Posts: 9,232
OK
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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
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Diamond Poster
Joined: Apr 2013
Posts: 2,267
The West
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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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#2021208 - 06/18/15 03:09 PM
Re: Effective Date Delayed
trying_to_comply
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10K Club
Joined: Nov 2002
Posts: 20,656
The Swamp
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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
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Power Poster
Joined: Oct 2009
Posts: 9,232
OK
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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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#2021219 - 06/18/15 03:32 PM
Re: Effective Date Delayed
trying_to_comply
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Power Poster
Joined: Oct 2009
Posts: 9,232
OK
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Oh yes, we were...just re-read it. Ok.
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#2021249 - 06/18/15 04:55 PM
Re: Effective Date Delayed
trying_to_comply
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Junior Member
Joined: Mar 2015
Posts: 42
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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
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Platinum Poster
Joined: Aug 2005
Posts: 914
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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
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Platinum Poster
Joined: Jan 2015
Posts: 652
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^^^^^^LIKE
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#2021267 - 06/18/15 05:45 PM
Re: Effective Date Delayed
trying_to_comply
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10K Club
Joined: Nov 2002
Posts: 20,656
The Swamp
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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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Platinum Poster
Joined: Aug 2010
Posts: 528
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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
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Gold Star
Joined: Nov 2004
Posts: 313
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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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#2021280 - 06/18/15 06:24 PM
Re: Effective Date Delayed
trying_to_comply
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Power Poster
Joined: Oct 2009
Posts: 9,232
OK
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The day after i retire would be a good time.
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#2021283 - 06/18/15 06:29 PM
Re: Effective Date Delayed
Sage
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Gold Star
Joined: May 2005
Posts: 298
Maryland
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I guess there was a "changed circumstance"... Love it!
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