Of course we can't know when the court case will be resolved. The plaintiffs have filed a brief asking for summary judgment invalidating the regulation based on their arguments (some of which are pretty questionable). They want the CFPB to start over with a new proposal. The CFPB has filed a brief asking for summary judgment in its favor, arguing against each of the plaintiff's claims.
And the court has issued a scheduling order for next events: the trade groups must file their reply in support of their motion for summary judgment and opposition to the Bureau’s cross-motion for summary judgment by November 20. The Bureau must file its reply in support of its cross-motion by December 18.
So nothing is going to happen before December 18 and probably not before the end of the year.
As a result, you can be assured the Bureau will have to address the compliance date and delay it to a future date. When that might be (assuming the Bureau wins the court case) is anyone's guess.
Oh, there's one other fly in the ointment -- a suit has been filed on behalf of a consumer group arguing that the Bureau's rescission of the ATP requirements of the rule was arbitrary and failed to take consumer comments into account, etc., etc.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8