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CFPB Director Richard Cordray defended the Aug. 1 date for the Truth in Lending Act and Real Estate Settlement Procedures Act integrated mortgage disclosure rule in his reply to lawmakers who asked for a five-month "hold harmless" period for those working to comply with the rule.

House subcommittee chairmen Blaine Luetkemeyer, R-Mo., and Randy Neugebauer, R-Texas, asked Cordray for the "hold harmless" period in a March 27 letter. Luetkemeyer and Neugebauer, who chair the House Financial Services Subcommittee on Housing and Insurance and Subcommittee on Financial Institutions and Consumer Credit, respectively, said the rule's effective date of Aug. 1 falls in one of the busiest months for home-loan closings.

Cordray, who responded in a letter dated April 22, deflected their argument by stating that August might be a busy month for home-loan closing, but not for new applications, which this new rule applies to. "We received extensive feedback that August was a comparatively better choice, given other operational imperatives for industry associated with the beginning of the calendar year and the traditionally slow pace of new applications in August," Cordray wrote.

Cordray did not say whether he would take into consideration a financial institution's good-faith efforts after the Aug. 1 deadline. In March, NAFCU, with several other financial trades, asked Cordray for a "grace period" or "restrained enforcement and liability" for institutions complying in good faith with the rule after Aug. 1 through year-end.

Earlier this month, NAFCU lodged support for H.R. 2213, introduced by Reps. Steve Pearce, R-N.M., and Brad Sherman, D-Calif., which would introduce a reasonable hold-harmless period through the end of 2015 for the rule.

The bill would give financial institutions through Dec. 31 to make a good-faith effort to comply with the new regulation without threat of enforcement actions or lawsuits. NCUA already indicated to NAFCU it will focus on good-faith efforts at compliance early on.