CUNA is overall supportive of proposed changes to the Truth in Lending Act-Real Estate Settlement Procedures Act integrated disclosure (TRID) rule, but asks the Consumer Financial Protection Bureau (CFPB) to continue to work on existing issues. CUNA submitted its comment letter Monday to the bureau on the proposed changes.
“Our request, however, is that the CFPB continue to engage in rulemaking and otherwise continue to provide both formal and informal guidance to the industry on a more frequent basis for those issues that continue to impede implementation of the TRID rule,” the letter reads. “We appreciate that the CFPB has engaged in outreach efforts such as the publication of the small entity compliance guide and various webinars, however, the CFPB can and should do more.”
Additional areas CUNA believes the CFPB should address include:
CUNA also supports several of the proposed revisions, including:
In response to the CFPB’s proposed effective date of 120 days after the final rule’s appearance in the Federal Register, CUNA believes August would be the best time, due to a lower volume of closings.