CUNA seeks clarification about discrepancy in TRID implementation
In a letter sent Friday, CUNA asked the Consumer Financial Protection Bureau (CFPB) to clarify an inconsistency and to exempt credit unions that make five or fewer mortgages in a calendar year from the Know Before You Owe rule, which includes the Truth-in-Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) integrated disclosures (TRID) rule.
Last week the CFPB extended the effective date of this rule from its original date of Aug. 1 to Oct. 1. (See related story: Missed deadline by CFPB factor in TRID delay.)
In the letter to CFPB Director Richard Cordray, CUNA noted a discrepancy between the CFPB’s previous TILA-RESPA Small Entity Compliance Guide and supplementary information to the TRID rule compared with text in the latest Small Entity Compliance Guide and the final rule text.
“Now that the effective date for the regulation has been extended, we believe there is adequate time for the CFPB to correct this inconsistency so that the lending operations of credit unions are not negatively impacted and members can continue to receive financial services to meet their needs,” CUNA wrote.continue reading »