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Ben Olson and Michelle Rogers Quoted in Inside Mortgage Finance Article, "CFPB Is Now Examining for TRID Compliance. Does This Mean the Grace Period is Over? We'll See"

Michelle L. Rogers, Benjamin K. Olson

Ben Olson and Michelle Rogers were quoted in Thomas Ressler's Inside Mortgage Finance article, "CFPB Is Now Examining for TRID Compliance. Does This Mean the Grace Period is Over? We'll See," on May 26, 2016. 

Examination reviews by the Consumer Financial Protection Bureau for compliance with the integrated disclosure rule known as TRID are now in full swing, according to leading industry attorneys.

That was the biggest take-away from a panel of three legal experts who were featured in a webinar hosted by Inside Mortgage Finance late last week that focused on CFPB examinations and how lenders can navigate their way through them. Although TRID was not a key focus of the webinar, it did come up as a topic during the question-and-answer period.

The attorneys were asked if TRID compliance exams are something lenders need to worry about now or further into the future. Michelle Rogers, a partner in the Washington, DC, office of the Buckley Sandler law firm, said briefly, “We have them right now.”

Rogers was asked after the event if the fact that TRID compliance exams are already underway means the bureau’s “soft enforcement” period is over. “Not necessarily,” she responded. “While the CFPB is always quick to point out that there is no grace period for TRID compliance, bureau staff continue to state, publicly and privately, that initial TRID exams will be diagnostic rather than punitive.”

Her colleague Ben Olson, a partner at Buckley Sandler, was asked how he thinks the consumer regulator will regard lenders and their compliance thus far. “While the bureau appears to be surprised and disappointed by the extent to which lenders and their systems vendors have struggled to implement TRID, its public statements have sought to reassure both lenders and investors that the liability associated with TRID errors is less than many believe,” said Olson, a former deputy assistant director in the CFPB’s Office of Regulations.

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