Personally, it doesn't seem to me that the extra two months is going to provide too much benefit. Those who will have been ready by October 1st would have probably also been ready by August 1st. And those who wouldn't have been ready by August probably still won't be ready by October 1st. It's possible that the short grace period is only going to serve as an incentive for those who have fallen behind to place even less emphasis on getting prepared.
In the June 15th episode of the Lykken on Lending
podcast I host, my colleague Alice Alvey brought up an interesting point. Even though the CFPB is offering some lenience to those who have made a good faith effort to prepare for TRID, that isn't going to stop the lawyers from filing suits. Lenience isn't law. And, until there is a change in law, the urgency for preparation is just as pressing now as it has been over the past year. My suggestion is to not use the CFPB's promise of lenience as a license for growing lax in preparation. It's always better to be safe than sorry.
A few weeks ago, the CFPB announced somewhat of an extension on the deadline for TRID. The hard deadline, it appears, has been moved from August 1st to October 1st of this year. Many in the industry are seeing this as a small victory, given the enormous amount of pressure the industry has placed on the CFPB for more time. Still, though, many are saying that two months just isn't going to be enough time.