WASHINGTON (7/7/15)--CUNA continues to push the Consumer Financial Protection Bureau (CFPB) to implement a safe harbor for legal liability and enforcement for its Truth in Lending Act-Real Estate Settlement Procedures Act integrated disclosures (TRID) rule.
In a letter sent Monday to the CFPB, CUNA highlights the importance of allowing mortgage industry participants time to properly plan for compliance.
The CFPB has proposed a delay in the TRID effective date to Oct. 3--pushing it back from the current Aug. 1 deadline. This action comes after CUNA and a number of legislators requested a safe harbor through the end of 2015.
The bureau also requested comments on alternative implementation dates. CUNA requested the CFPB extend the implementation date to Jan. 1, 2016, along with a corresponding safe harbor, to allow credit unions and others to tackle the complexities of the new rule.
“We note that many credit unions will need to run dual tracks during the transition to provide for those loans whose applications are received before the effective date versus those received after the effective date as provided in the rule,” the CUNA letter warns.
CUNA reaffirmed its request--also expressed in its June 19 letter to the CFPB--that the bureau confirm that creditors that make five or fewer mortgages per year are exempt from TRID. The rule’s small entity compliance guide published in June removed specific language exempting such creditors from the rule.
“We urge the CFPB to address this issue so that the lending operations of credit unions are not negatively impacted and members can continue to receive financial services to meet their needs,” the letter reads.