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Washington
TILARESPA proposal published in iFederal Registeri
WASHINGTON (8/24/12)—With the comment period on key terms such as finance charges due Sept. 7, the Consumer Financial Protection Bureau (CFPB) Thursday published in the Federal Register its recently proposed amendments to Regulation Z, Truth in Lending Act (TILA), and Regulation X, Real Estate Settlement Procedures Act (RESPA), to combine certain home mortgage disclosures.

The CFPB proposed new mortgage disclosure form and the RESPA and TILA proposed changes last month.

The mortgage proposal would apply to the majority of consumer mortgages, but would not apply to home equity lines of credit, reverse mortgages, or mortgages that are secured by mobile homes or dwellings that are not attached to land. Creditors that process five or fewer mortgages per year would also not be subject to the rules.

The Credit Union National Association (CUNA) continues to review the 1,099 page proposal, and is concerned by a CFPB claim that the proposed mortgage changes would not increase the cost of mortgage lending. "A dollar spent on regulatory compliance is a dollar diverted from lending. So, in fact, some mortgage reforms in the Dodd-Frank Act do negatively impact access to mortgage credit for consumers," CUNA has said.

CUNA is also focusing on how the rule's proposed revision of the finance charge definition could impact credit unions.

CUNA has received credit union comments on how elements of the CFPB proposals, including a section that would require lenders to include most up-front costs associated with a mortgage in their finance charge, could be improved.

Additional CUNA comment calls and surveys on other aspects of the proposed mortgage rule are still under development.

The mortgage form and proposed rules are scheduled to be finalized in January.

However, CUNA has encouraged members of the U.S. Congress to support extending the compliance date for these pending mortgage rules, and to urge the CFPB to exempt credit unions from the mortgage rules where possible.

For the full CFPB release, as published in the Federal Register, use the resource link.
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