Comments on TILA-RESPA amendments, servicemember credit due this month

November 3, 2014

WASHINGTON (11/4/14)--Comments on small amendments to the Consumer Financial Protection Bureau's (CFPB) new mortgage rules and the proposed changes to the Military Lending Act (MLA) are due to their respective agencies this month.

The CFPB's proposal would make two changes to the upcoming Truth in Lending Act-Real Estate Settlement Procedures Act (TILA-RESPA) integrated disclosures rule, which will become effective Aug. 1, 2015.

The changes are:

  • Allowing creditors extra time to provide consumers with a revised Loan Estimate form after a floating interest rate has been locked. The current rule requires the revised form be provided the same day; and

  • Allowing 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.

Comments on the proposal are due to the CFPB by Nov. 10.

The changes to the MLA would establish a maximum military annual percentage rate (MAPR) of 36% that could be charged on closed-end consumer credit transactions.

Some, including the Credit Union National Association and Defense Credit Union Council, along with the National Credit Union Administration, have expressed reservations about the proposal.

NCUA Chair Debbie Matz has said the proposal could affect credit unions who offer payday alternative loans. Many credit unions charge an interest rate on such loans up to 28% and an application fee of $20. The new proposal would include application fees in the 36% cap.

Comments are due to the Department of Defense by Nov. 28. Comments on the MLA proposal can also be submitted to CUNA by Friday.