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NAFCU's Carrie Hunt yesterday urged CFPB Director Richard Cordray to ensure credit unions have adequate time to comply with a series of mortgage-related rules expected to be finalized in 2013.

In fact, given the interplay between several of these rules and the TILA/RESPA rules and disclosures, he urged that the bureau put off setting any compliance deadlines until the TILA/RESPA package is itself published in final form.

The CFPB has rules still in draft stage that would define "qualified" mortgage for purposes of the ability-to-repay mortgage rule, rules on high-cost mortgages, loan originator compensation and appraisal reforms. "Each of these rules is very likely to be burdensome independently," wrote Hunt, NAFCU's general counsel and vice president of regulatory affairs. All five are expected to become final before Jan. 21, and credit unions "will face unprecedented challenges to digest, understand and implement the regulations," Hunt added.

In NAFCU's view, the CFPB has discretionary authority to provide much more time for compliance than the 12 months the bureau has discussed publicly with respect to some rules. Hunt said too brief a compliance period could lead many institutions to improperly implement the final rules.

The CFPB could also use its broad authority to consider the regulatory burden for small entities, Hunt continued, and provide a later compliance deadline for all credit unions.

• NAFCU comment letter