Feb. 5, 2013 – Credit unions’ concerns about the CFPB’s proposed, combined mortgage disclosures were aired at length in a meeting at the bureau’s headquarters Monday among CFPB Director Richard Cordray, senior CFPB staff and representatives from the NAFCU staff and board.
The meeting focused on the CFPB’s proposal to harmonize the mortgage disclosures required under the Truth in Lending Act and Real Estate Settlement Procedures Act. The proposal and disclosure forms, in the works for more than two years, aren’t expected to be released in final form for at least another six months.
Monday’s discussion covered a number of key issues, among them:
- the definition of finance charge;
- the rule’s proposed treatment of third-party fees, including fees assessed by institution affiliates and non-affiliated firms;
- the timing of disclosures required in connection with loan application and at settlement;
- tolerances for the differences between estimated fees and costs and actual fees and costs.
NAFCU is urging the CFPB to ensure its final mortgage rules are not unduly burdensome to credit unions, do not create more confusion for consumers and do not lead to a decline in credit availability.
The association is also pressing for a minimum, 18-month implementation period beginning from the time the rules are finalized.
Martin Breland, NAFCU’s Region II board director and president of Tower FCU, participated in Monday’s discussion with Cordray and other bureau staff. Also participating were association President and CEO Fred Becker, Executive Vice President of Government Affairs Dan Berger, General Counsel and Vice President of Regulatory Affairs Carrie Hunt, Senior Regulatory Affairs Counsel Tessema Tefferi, Director of Regulatory Compliance Steve Van Beek and Regulatory Affairs Counsels PJ Hoffman and Angela Meyster.