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Removing Barriers Blog

CUNA Continues to Advocate for Clarity about TRID Implementation
Posted June 26, 2015 by CUNA Advocacy

On Wednesday, June 23 CUNA held a phone call with CFPB staff as a follow-up to President/CEO Jim Nussle’s letter to the CFPB expressing our concerns and seeking clarity about a discrepancy related to the scope of new requirements for the TILA-RESPA integrated disclosures rule.  

In conversations with the CFPB, and in the letter, CUNA expressed concerns that the final rule offers a different description of the scope of the rule than both the guide that the Bureau issued in September 2014 to help small financial institutions understand how to comply with the new rule and the supplementary information that accompanies the rule. During CUNA’s call with the CFPB, Bureau staff indicated that they do not believe that credit unions making five or fewer mortgages in a calendar year are exempt from the rule if they also offer 25 total loans in accordance with Regulation Z. CUNA staff then questioned the CFPB why supplementary rule information and the Small Entity Compliance Guide indicated otherwise. The CFPB replied that after CUNA brought this discrepancy to its attention, the Small Entity Compliance Guide was amended in June, and also the CFPB noted that credit unions should not rely on these guides because of the disclaimers they contain.  

CUNA staff expressed deep concerns that making this change so close to time for implementation is very problematic for our credit unions that have relied on the previous publications from the CFPB, particularly the more than 700 credit unions that will be impacted by this change. After urging from CUNA, CFPB staff indicated that it may make a more public announcement about any changes to the Small Entity Compliance Guide or supplemental rule information to help provide much needed clarity on this issue.  

The CFPB also put out official notice that the effective date of the TILA-RESPA integrated disclosures rule rule will be delayed until Oct. 3, a Saturday, instead of Oct. 1.