Aug. 15, 2012 – NAFCU Vice President of Regulatory Affairs Carrie Hunt and NAFCU Regulatory Affairs Counsel Dillon Shea will meet with the Consumer Financial Protection Bureau today to discuss proposed rule changes relating to credit union mortgage lending practices.
The CFPB is proposing to combine disclosures under the Truth in Lending Act and Real Estate Settlement Procedures Act, as well as the agency’s Home Ownership and Equity Protection Act proposed rule. Both proposals were unveiled July 9: the TILA/RESPA proposal was 1099 pages; the HOEPA rule was 293 pages.
From the very beginning, NAFCU has been working with the CFPB to ensure credit unions concerns were heard as the proposals were developed. The CFPB is aiming to make the process easier by streamlining the loan estimate and loan closing form process. In both cases, a single form would be required, rather than the two forms currently required. The loan estimate form must be given within three business days after the consumer applies, and the loan closing form must be provided three days prior to closing.
The proposals apply to most closed-end mortgages, but do not apply to home-equity lines of credit, reverse mortgages, or mortgages secured by a mobile home or loan made by a creditor that makes five or fewer loans a year.
The CFPB has yet to indicate when a final rule may be coming on the TILA/RESPA proposal. The HOEPA rule needs to be finalized by Jan. 21, 2013.
Credit unions with questions are encouraged to view a NAFCU webcast on the TILA/RESPA and HOEPA proposals hosted by Hunt and Steve Van Beek, the association’s director of regulatory compliance. The webcast, which originally aired in July, is archived here.
NAFCU has issued Regulatory Alerts on the above proposals and is seeking members' feedback.