WASHINGTON (11/13/14)--Recent revisions to the Consumer Financial Protection Bureau's Truth in Lending Act-Real Estate Settlement Procedures Act (TILA-RESPA) rules have the general support of the Credit Union National Association, according to a letter filed to the bureau this week.
The letter, signed by CUNA Associate General Counsel Jared Ihrig, also urges the bureau to continue to search for ways to ease the regulatory burden on credit unions.
The proposal modifies two parts of the TILA-RESPA integrated disclosures rule.
Currently, creditors must provide the revised Loan Estimate form the same day the customer locks in their floating interest rate. The modification would allow them to provide the revised form the next business day.
"CUNA fully supports the CFPB's proposal to relax the timing requirement for providing a revised disclosure in this regard to the next business day after the date the rate is locked, but would encourage the bureau to extend the proposed timeframe by an additional business day," the letter reads.
"For small credit unions, it is not always possible to generate the revised disclosures within one business day of the rate being locked; therefore we urge the bureau to consider allowing creditors to provide a revised Loan Estimate no later than two business days after the date the rate is locked, instead of just one business day thereafter."
The second modification, supported by the CUNA, would allow creditors to include language informing consumers that a revised Loan Estimate form may be issued for a construction loan that is expected to take more than 60 days to settle.
In the letter, CUNA also urged the bureau to "continue listening to industry concerns and to evaluate the extent to which the agency's rules need further clarifications or amendments that would ease the compliance burden for credit unions and others that are subject to these rules."
The revised TILA-RESPA rule will become effective Aug. 1, 2015.