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.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8