WASHINGTON–CUNA and NAFCU have each sent a letter to the CFPB regarding amendments to the Federal Mortgage Disclosure Requirements under the Truth in Lending (Regulation Z) (TRID Amendments).
CUNA said that while overall it is supportive of the proposed changes, it wants to see the agency “engage in rulemaking and otherwise continue to provide both formal and informal guidance to the industry on a more frequent basis.”
“We appreciate that the CFPB has engaged in outreach efforts such as the publication of the small entity compliance guide and various webinars, however, the CFPB can and should do more,” CUNA said in its letter. “For example, searchable written transcripts of the webinars would be greatly appreciated by credit unions, as would published Frequently Asked Questions that are updated regularly that address common questions. We are unclear as to the CFPB’s hesitancy to provide these methods of communicating its interpretation of various compliance issues, as these resources are common with other agencies.”
CUNA also raised concerns around implementation of the proposed rule.
A complete copy of CUNA's comment letter can be found in CUToday.info’s The gov here.
In its comment letter NAFCU urged the Bureau to extend the implementation period in its proposal.
"Specifically, a period of at least nine to twelve months would give credit unions and their vendors the necessary time to test their systems in a real-world setting prior to the effective date of these amendments, thereby reducing the risk of process errors and consumer confusion. However, since there are a number of positive aspects of the rule that credit unions may want to implement on an earlier timeline, the Bureau should allow for early compliance but not require these changes to be implemented in a manner that would tax credit union regulatory compliance divisions and vendors,” wrote NAFCU Executive Vice President of Government Affairs and General Counsel Carrie Hunt. “NAFCU recommends incorporating guidance into the Bureau’s Official Interpretations to Regulation Z that indicates that a negative number is permissible if that is what the formula provides. Insofar as this issue may also impact the “Cash to Close” table, which incorporates amounts disclosed under paragraph (f) and (g) of Section 1026.37, the Bureau should consider incorporating guidance on negative numbers in that commentary as well.”
Hunt continued by saying, “NAFCU recommends that the Bureau clarify that pre-approvals are a different stage of the loan application process, and as long as consumers are clear that a preapproval, and not a loan, is being sought, any information needed by the credit union may be requested from the consumer to provide a pre-approval or pre-qualification without triggering disclosures. In the alternative, the CFPB could clarify that although pre-approvals are a different stage of the process (a) the credit union may not request all six items of information for an application and (b) the consumer may voluntarily provide all information required by the credit union, if a pre-approval is sought.”
A complete copy of NAFCU's comment letter can be found in CUToday.info’s The gov here.