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Other Areas Of the Delay NPRM

Other Areas Of the Delay NPRM

Unanticipated Possible Hurdles to Compliance

As talked about within the Delay NPRM, the Bureau’s 2nd reason behind proposing to wait the conformity date for the Mandatory Underwriting Provisions ended up being that the Bureau had discussed execution efforts with a quantity of industry individuals since book of this 2017 last Rule. Through these conversations, the Bureau had received reports of numerous unanticipated possible hurdles to compliance because of the Mandatory Underwriting Provisions by the August 19, 2019 conformity date. The Bureau sought to better understand these reported obstacles and exactly how they could keep on perhaps the Bureau should postpone the August 19, 2019 conformity date for the Mandatory Underwriting Provisions although it considers whether or not to rescind those portions associated with 2017 Final Rule. (more…)