October 30, 2013
The Honorable Richard Cordray
Director
Consumer Financial Protection Bureau
1700 G Street, NW
Washington, DC 20552
RE: Delay of Effective Dates of the CFPB’s Mortgage Rules
Dear Director Cordray:
On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association that exclusively represents federal credit unions, I am writing to request that the Consumer Financial Protection Bureau (CFPB) delay the effective dates of each of the mortgage-related rules scheduled to be effective in January 2014. We request that the CFPB delay the effective dates by at least 12 months.
In January 2013, the CFPB issued seven significant mortgage-related rules, each with an effective date in January 2014. The rules directly affect or indirectly impact every aspect of a credit union’s mortgage operations, including origination, servicing, loan originator compensation, escrow, insurance-related matters, and appraisals. While we appreciate the CFPB’s efforts to provide guidance, as well as credit unions’ own best efforts to ensure they are ready and able to comply by the effective dates of the various rules, many credit unions are facing unprecedented difficulties and incurring significant costs. In this regard, we ask you to consider that credit unions are non-profit cooperative entities that rely on retained earnings as their sole source for capital; accordingly, delaying the effective dates of the rules is crucial.
NAFCU is working tirelessly to help our members navigate through the complex and voluminous regulations, but it has become very clear that many credit unions need additional time.
I appreciate your attention to our request. NAFCU looks forward to continuing to work with the CFPB on these and other issues. If you have any questions or concerns, please feel free to contact me at (703) 842-2215 or Tessema Tefferi at (703) 842-2268.
Sincerely,
B. Dan Berger
President and CEO