WASHINGTON (9/19/12)--Credit unions can detail the compliance costs and regulatory burdens associated with the Consumer Financial Protection Bureau's (CFPB) pending proposal on mortgage servicing, and the efforts it will take to implement these changes, in a new Credit Union National Association (CUNA) Comment Call.
The Comment Call is one of several released by CUNA on recent CFPB's proposals.
The proposed rules regarding mortgage servicing would amend Regulation Z, which implements the Truth in Lending Act (TILA), and Regulation X, which implements the Real Estate Settlement Procedures Act (RESPA). The regulations would coordinate with changes proposed in connection with the combined TILA and RESPA forms that will be provided for most closed-end mortgage loans.
The mortgage forms and proposed rules are scheduled to be finalized by January.
In this latest Comment Call, CUNA has asked for information from credit unions on what types of exemptions might be appropriate for small servicers and how much time credit unions will need to effectively implement the mortgage changes. The Comment Call also notes that the CFPB has sought comment on the impact of delayed implementation on consumers and on other market participants.
Credit unions may also comment on the CFPB's proposed payoff statements, timing requirements for periodic statements, and their own methods of combining financial statements for their members. Comments on rate changes, late fees, and prepayment penalty changes are also requested in the Comment Call.
For the full CUNA Comment Call, use the resource link.