NAFCU supportive of changes to CFPB’s Regulation Z rule

WASHINGTON, DC (November 17, 2017) — National Association of Federally-Insured Credit Unions (NAFCU) Regulatory Affairs Counsel Andrew Morris today in a letter to the Consumer Financial Protection Bureau (CFPB), said the association is supportive of the bureau’s efforts to address the statement timing provisions connected with a consumer’s bankruptcy case housed in the Regulation Z mortgage servicing rules.

The CFPB’s proposed amendments would allow a single-statement exemption at any point in the billing cycle related to the use of modified or unmodified periodic statements or coupon books used with bankruptcy cases. Morris told the CFPB this change would “vastly reduce the complexity associated with tracking and monitoring discrete triggering events in consumer bankruptcy actions.”

Morris also recommended that the small-servicer exemption be expanded to give more regulatory relief to credit unions. He said while some credit unions do qualify for the exemption, many others remain ineligible and “would experience severe strain once successor in interest and bankruptcy periodic statement provisions go into effect.”

The CFPB’s mortgage servicing rules are set to take effect in April.



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 or @NAFCU on Twitter.


Molly Safreed, (NAFCU)

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