NAFCU urges CFPB to make TILA assessment, RESPA fixes

WASHINGTON, DC (July 8, 2017) — The National Association of Federally-Insured Credit Unions (NAFCU) on Friday urged the Consumer Financial Protection Bureau (CFPB) to reverse its decision not to perform a five-year assessment of its Truth in Lending Act (TILA) rule, noting the suggestion that the TILA is not a “significant” rule “is divorced from common sense and real world experiences.”

In an official comment letter also urging fixes for the Real Estate Settlement Procedures Act rule, NAFCU Regulatory Affairs Counsel Ann Kossachev said the TILA rule presents a regulatory burden comparable in impact to that of the RESPA rule. The two were issued together as the CFPB’s TILA/RESPA integrated mortgage disclosures rules, or TRID.

Under the Dodd-Frank Act, the CFPB must conduct assessments of “significant” rule five years after they take effect.

Kossachev said assessing the RESPA rule but not the TILA rule “will leave the CFPB with an inaccurate understanding of the regulatory framework and costs and benefits of the implementation of the mortgage servicing rules” issued following the recession. She urged the bureau to reconsider.

In the meantime, Kossachev urged changes to the model forms required for disclosures on force-placed insurance and requirements for loss mitigation under the RESPA regulation.


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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