Press
NAFCU letter in advance of hearing,” TILA-RESPA Integrated Disclosure: Examining the Costs and Benefits of Changes to the Real Estate Settlement Process”
May 13, 2015
The Honorable Blaine Luetkemeyer
Chairman
Subcommittee on Housing and Insurance House Financial Services Committee
United States House of Representatives
Washington, DC 20515
The Honorable Emanuel Cleaver
Ranking Member
Subcommittee on Housing and Insurance House Financial Services Committee
United States House of Representatives
Washington, DC 20515
Re: Tomorrow’s Hearing: “TILA-RESPA Integrated Disclosure: Examining the Costs and Benefits of Changes to the Real Estate Settlement Process”
Dear Chairman Luetkemeyer and Ranking Member Cleaver:
On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association that exclusively represents the interests of our nation’s federal credit unions, I write regarding tomorrow’s subcommittee hearing entitled “TILA-RESPA Integrated Disclosure: Examining the Costs and Benefits of Changes to the Real Estate Settlement Process.” We thank you for your attention to this important matter.
As you are aware, the CFPB issued a new TILA/RESPA rule in 2013 that combines the Good Faith Estimate and the initial Truth-in-Lending disclosure into the new Loan Estimate form. Among other things, the rule requires credit unions to completely restructure their technology systems and business processes in order to comply with a host of new disclosure and timing requirements.
NAFCU’s member credit unions have been working tirelessly with their staffs and their vendors to navigate through the complex and voluminous TILA/RESPA rule. While NAFCU firmly believes that our members have taken the steps necessary to be in compliance as of the August 1, 2015, effective date, we are concerned that credit unions have been restricted in their ability to conclusively test their new platforms for strict compliance with the TILA/RESPA rule.
Because the CFPB has prohibited early compliance with the TILA/RESPA rule, credit unions are unable to efficiently and thoroughly test their new systems today. Instead, they are forced to operate two platforms – one that supports the current Good Faith Estimate and the initial Truth-in-Lending disclosure, and one that supports the new Loan Estimate form.
We are pleased that the National Credit Union Administration (NCUA) Chairman Debbie Matz announced to NAFCU earlier this year that the agency will consider credit unions’ “good faith efforts toward substantial compliance” with the new TILA/RESPA rule for credit unions the agency examines. We believe such a policy should be implemented by the CFPB as well, which is why we support legislation introduced by Representatives Steve Pearce and Brad Sherman, H.R. 2213, which would create a safe harbor of “good faith compliance” through December 31, 2015. We urge the committee to support this legislation.
Thank you for the opportunity to share our thoughts on this important issue for credit unions. If you have any questions or would like further information, please do not hesitate to contact me or NAFCU’s Director of Legislative Affairs, Jillian Pevo, at (703) 842-2836 or jpevo@nafcu.org
Sincerely,
Brad Thaler
Vice President of Legislative Affairs
cc: Members of the House Financial Services Subcommittee on Housing and Insurance