WASHINGTON, DC (September 30, 2015) —
HUD Desk Officer
Office of Management and Budget
New Executive Office Building
Washington, DC 20503
RE: Notice of Proposed Information Collection: Application for FHA Insured
Mortgages (Docket No. FR-5831-N-39)
Dear Sir or Madam:
On behalf of the National Association of Federal Credit Unions (NAFCU), the only national trade association focusing exclusively on federal issues affecting the nation’s federally insured credit unions, I am writing to you regarding the second notice seeking public comment by the U.S. Department of Housing and Urban Development (HUD) on its proposed revisions to the “HUD Addendum to Uniform Residential Loan Application” (Form 92900-A). See 80 FR 52783 (September 1, 2015). NAFCU commends HUD for incorporating the industry’s suggestions into the current version and recommends the Department continue to update its forms with the goal of eliminating the burden caused by duplicative and confusing paperwork.
NAFCU supports HUD’s second revision of Form 92900-A, which is used to determine whether a borrower in a proposed mortgage transaction is eligible for the Federal Housing Administration’s (FHA’s) insurance endorsement. NAFCU also appreciates HUD’s acknowledgement of the competing priorities facing credit unions as we approach the October 3 implementation date of the Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) Integrated Disclosure (TRID) Rule. Over the coming months, financial institutions will be working diligently to overcome the inevitable growing pains of the onerous and complex framework created by the TRID Rule. Accordingly, NAFCU believes HUD’s estimated November 2015 implementation date for the revised Form 92900-A provides credit unions with adequate time to implement the amended form.
HUD’s continued efforts to improve the clarity of its forms will allow credit unions to continue to work with borrowers in a manner that minimizes both confusion and regulatory burden. NAFCU appreciates the opportunity to share its thoughts on the proposed revisions to Form 92900-A. Should you have any questions or concerns, please feel free to contact me at amonterrubio@nafcu.org or (703) 842- 2244.
Sincerely,
Alexander Monterrubio
Regulatory Affairs Counsel
The National Association of Federally-Insured Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation’s federally-insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance. For more information on NAFCU, go to www.nafcu.org or @NAFCU on Twitter.
