news.cuna.org/articles/107477-fha-insurance-changes-need-more-thought-cuna

FHA insurance changes need more thought: CUNA

September 9, 2015

WASHINGTON (9/9/15)--Federal regulators must act to provide certainty that credit unions and other financial institutions will not be unduly hampered by the threat of enforcement orders while they act in good faith to meet the "significant implementation challenges” of the new TILA/RESPA Integrated Disclosure (TRID) rule that goes into effect Oct. 3.

CUNA and other financial trade associations joined forces in a letter sent Friday to underscore the urgent need of formal regulatory guidance. Without it, the letter warns, the "fear of enforcement actions for errors committed while acting in good faith will severely constrain consumer access to needed mortgage credit." 

In June, CFPB Director Richard Cordray announced his agency would grant mortgage lenders leniency on the TRID implementation date.  

However, the letter urges the Federal Financial Institutions Examination Council (FFIEC) to articulate "precise policies for examining and supervising financial institutions for the initial months after the TRID implementation date."

CUNA and partners also ask the FFIEC to:

  • Provide a clear transition period that addresses how regulators will oversee and examine regulated institutions for TRID compliance during this transition period; and
  • Establish predictable regulatory restraint by enunciating clear guidelines that, if met in good faith, would afford institutions with enforcement and examination relief for a reasonable time period following Oct. 3.  

The FFIEC is comprised by the heads of the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Consumer Financial Protection Bureau, the National Credit Union Administration, the Office of the Comptroller of the Currency, and a state financial regulatory bureau.