WASHINGTON (7/25/11)--The Credit Union National Association has urged the Federal Reserve to clarify portions of proposed Truth in Lending Act (TILA) changes to “ensure continued consumer access to mortgage credit at fair rates and to avoid unnecessary regulatory burden and unintended consequences.” The Fed changes, which are required under the Dodd-Frank Act, would expand TILA’s ability-to-repay requirements to cover any consumer credit transaction secured by a dwelling, other than open-end credit plans, timeshare plans, reverse mortgages, or temporary loans. CUNA in a Friday comment letter said it generally supports the proposal, but asked the Fed to clarify portions of the proposal addressing lower-documentation loans. A proposed “evasion” prohibition could also be clarified, as the prohibition, as written, could lead some credit unions to believe they cannot offer many open-end mortgage products to their members. While it backed the Fed’s ability-to-repay analysis standards, CUNA added that these standards will cause few issues for credit unions, as they “have historically engaged in safe and sound mortgage underwriting. “Requiring all mortgage lenders to follow similar ability-to-repay mortgage underwriting criteria will help eliminate abusive practices” and make it easier for consumers to compare mortgage products, CUNA added. CUNA also encouraged the Fed to delay the compliance date for these requirements. For the full comment letter, use the resource link.