NAFCU Statement on CFPB’s Proposed TILA / RESPA and HOPEA Rules
WASHINGTON—The National Association of Federal Credit Unions (NAFCU) affirmed that it will continue to seek changes to a proposal combining the Truth in Lending Act and Real Estate Settlement Procedures Act (TILA/RESPA -Regulation Z) and Homeownership Counseling Amendments to the Real Estate Settlement Procedures Act (Regulation X) released today by the CFPB.
NAFCU noted the detailed cost/ benefit analysis by the Consumer Financial Protection Bureau (CFPB) in the agency’s proposed rule but it will continue to press the case of credit union regulatory burden.
NAFCU has been working with the CFPB since its inception on the combined mortgage disclosures. The bureau has been working on this initiative, dubbed Know Before You Owe, for more than 18 months. The CFPB also issued a proposed rule today that would expand the types of mortgage loans that are subject to the protections of the Home Ownership and Equity Protection Act. This proposed rule would revise and expand the triggers for HOEPA coverage and would impose new restrictions, including a pre-loan counseling requirement.
The association supports streamlining mortgage disclosures, but noted the rule will have a big impact on credit union lending.
“With respect to compliance costs, NAFCU is focusing not only on this rule but on all the rules in place before the Dodd-Frank Act and those implemented under its mandates that, combined, present real problems for credit unions,” said Carrie Hunt, NAFCU’s general counsel and vice president of regulatory affairs.
“That said,” she continued, “we applaud the CFPB for its consistent effort to reach out to the credit union industry in its effort to draft a package that we all hope will serve consumers while imposing the least regulatory burden possible.”
As long urged by NAFCU, the proposed rule also contains a lengthy cost/benefit analysis that also addresses the impact on small entities. NAFCU has been pressing all regulators for such an analysis, and it has been continuously focused on the rules coming out of the CFPB, which affect all credit unions.
The National Association of Federal Credit Unions is the only national organization that focuses exclusively on federal issues affecting credit unions, representing its members before the federal government and the public.