Removing Barriers Blog

CUNA Comments on the CFPB’s proposed delay of the TILA-RESPA Integrated Mortgage Disclosures Rule
Posted July 06, 2015 by CUNA Advocacy

CUNA sent a letter to the CFPB on Friday commenting on their proposed delay to October 3, 2015 for implementation of the TILA-RESPA Integrated Mortgage Disclosures Rule. CUNA commented that it believed the additional two month period was a step in the right direction, but a delay until January 1, 2016 would be more appropriate given the magnitude of the changes and the costs associated with implementation.  CUNA reiterated its continuing call to implement a safe harbor for legal liability and enforcement.

Finally, CUNA called for the CFPB to confirm that creditors that make five or fewer mortgages per year, as outlined in the rule’s supplementary information and the September 2014 Small Entity Compliance Guide, are exempt from the TILA-RESPA rule.  There currently exists an inconsistency between the text of Regulation Z and the supplementary information and Guide.

For more information please contact Andy Price.