WASHINGTON (3/17/15)--CUNA has informed the Consumer Financial Protection Bureau (CFPB), in a comment letter filed Monday, that, while CUNA generally appreciates clarifications to the agency's rules, any rule changes inevitably impose a burden on financial institutions as they work to understand the impact of such changes.
The letter was sent in response to a CFPB proposed rule that would change bureau mortgage-servicing regulations that implement the Truth in Lending Act and Real Estate Settlement Procedures Act (TILA-RESPA).
"We recognize that adjustments and clarifications are inevitable when dealing with such voluminous regulations," reads the letter, signed by Luke Martone, CUNA senior director of advocacy and counsel. "However, we urge the Bureau to be cognizant of the fact that any changes and/or 'clarifications' to its rules impose a burden on entities in order to understand the impact of such revisions and to make any relevant updates to the institutions' systems or policies, as necessary."
According to CUNA, several proposed changes would ease the burden on credit unions with regard to mortgage servicing, but a number could be problematic for credit unions and other mortgage servicers.
Though CUNA is generally supportive of the proposed rule, it is recommending several improvements, including:
The letter asks that the bureau work closely with CUNA, credit unions and credit union leagues as it develops rules, in order to ensure subsequent revisions or clarifications maximize regulatory relief without undermining statutory objectives.