CUNA applauds MLO rule review, suggests modernizations

May 2, 2023

CUNA applauds the Consumer Financial Protection Bureau’s (CFPB) decision to review and consider modernization for its mortgage loan originator (MLO) rules. CUNA sent comments Monday in response to the review.

“By and large, credit unions report that over the last decade, they have successfully implemented policies and training to ensure compliance with the MLO Rule,” the letter reads. “While credit unions initially reported confusion or difficulty regarding disclosure of the NMLS ID information, the definitions, and training requirements during the implementation period, these appear to have been resolved.

“Compliance concerns regarding the application of these rules seem relatively infrequent and credit unions appear to have little difficulty working with their third-party vendors when necessary,” it adds.

Credit unions generally report their ability to compete for MLO talent is largely driven by market forces, and it appears the MLO compensation rules do not create barriers for credit unions.

CUNA also notes:

  • Credit unions desire the ability to hold MLOs partially responsible for losses that result from “significant errors” on the MLO’s part.
  • Credit unions report an increase in errors correlates with their inability to hold mortgage loan originators accountable through their compensation.
  • Credit unions expressed interest in additional guidance from the CFPB regarding compliant methods for holding mortgage loan originators accountable for disclosure errors related to individual costs and pricing terms on mortgage loans.