The Consumer Financial Protection Bureau (CPFB) cited CUNA’s Regulation Impact Study in its assessment on the TILA-RESPA Integrated Disclosure (TRID) rule. CUNA also submitted a comment letter in January on the assessment, noting that ongoing compliance costs continue to affect credit union lending.
The assessment found that TRID has made progress towards several of its goals but resulted in sizable implementation costs.
CUNA’s Regulatory Impact Study was cited as key source of data and information as a study that, “collected costs data and analyzes the cost that regulations, including the TRID rule, have had on credit unions and how these effects have changed over time.”
The evidence available for the assessment indicates that the TRID rule improved consumers’ ability to locate key information, compare terms and costs between initial disclosures and final disclosures, and compare terms and costs across mortgage offers.
Evidence was mixed, but leans positive, regarding whether the rule improved consumer understanding of forms.
In addition, the CFPB published a Data Point examining how the terms and costs of a mortgage loan may change during the origination process as reflected in the Loan Estimate and Closing Disclosure forms provided to borrowers pursuant to the TRID Rule.