CFPB: We’re aware abrupt ‘Juneteenth’ holiday observance raised concerns about disclosure compliance in mortgage closings

The timing of mortgage lenders’ compliance with federal disclosure rules may have been disrupted with the abrupt implementation of the new “Juneteenth” federal holiday late last week – perhaps even delaying mortgage closings – and the federal consumer financial protection agency said Friday it was aware of concerns those disruptions have raised.

In a statement, Consumer Financial Protection Bureau (CFPB) Acting Director Dave Uejio said the concerns revolved around mortgage lender compliance with Truth in Lending Act and TILA-RESPA Integrated Disclosure (TRID) timing requirements. “The CFPB recognizes that some lenders did not have sufficient time after the Federal holiday declaration to consider whether and how to adjust closing timelines,” Uejio wrote. “The CFPB understands that some lenders may delay closings to accommodate the reissuance of disclosures adjusted for the new Federal holiday.”

Uejio noted that both TILA and TRID requirements generally protect creditors from liability for bona fide errors and permit redisclosure after closing to correct errors.

The acting CFPB director said any guidance ultimately issued by the CFPB would consider the limited implementation period before the holiday and would be issued after consultation with both federal and state financial institution regulators “to ensure consistency of interpretation for all regulated entities.”

Statement by CFPB Acting Director Dave Uejio on Impact of the Juneteenth National Independence Day Federal Holiday on Residential Mortgage Closings

 

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