(July 7, 2014) -- Good afternoon,
Attached is NAFCU Regulatory Affairs Counsel Angela Meyster's letter to the Consumer Financial Protection Bureau (CFPB) regarding the Bureau's Request for Comment regarding a correction or cure of debt-to-income ratio overages and the credit extension limit for the small creditor definition.
In the letter, Meyster says the CFPB has already proposed amending Section 1026.43(e)(3)(iii) to allow a lender to cure certain situations in which it intended to originate a qualified mortgage in good faith but later discovered that they had inadvertently exceeded the points and fees threshold. Meyster says the association believes that there should be a similar cure or correction process for inadvertent errors related to a consumer’s debt-to-income (DTI).
Meyster also states NAFCU strongly recommends that the 500 or fewer transaction limit be raised considerably since this 500-transaction limitation is not only arbitrary, but it also does not comport with the realities of many small credit unions’ lending activities. She says the association believes the appropriate “small creditor” mortgage threshold should be 1,000 mortgages per year.
Meyster says NAFCU strongly supports the CFPB’s efforts to work with the industry to ease the burden of its regulations and to identify opportunities to benefit consumers further by amending regulatory requirements, but urges the CFPB, however, to consider the full scope of its regulatory process and to avoid a piecemeal, uncoordinated approach with competing timelines and changes.
If you would like more information on this matter or would like to speak about this with a NAFCU expert, please let me know.
Thank you.
Dana Kauffman
Communications Coordinator
National Association of Federal Credit Unions
3138 10th Street North
Arlington, VA 22201
Phone: 703-842-2235
Fax: 703-524-1082
dkauffman@nafcu.org