NAFCU President and CEO Fred Becker.
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March 15, 2013 – NAFCU President and CEO Fred Becker on Thursday recommended that the CFPB issue guidance combining all of its mortgage rules into “one uniform Regulation Z” to make the compliance process easier for credit unions.
In a March 14 letter to the bureau, Becker said the CFPB’s decision to issue its mortgage rules under Regulation Z and Regulation X has presented difficulties for credit unions. “As the rules currently exist,” Becker wrote, “a credit union must consult each of the final rules, the related staff commentary, and the final rules’ preambles,” he noted. “This process has already proved to be arduous and will make compliance far more difficult than necessary.”
Becker also recommended that the CFPB adopt a guidance process similar to other regulators where regulated entities can seek answers on unresolved or unclear issues. “Given the enormity and complexity of the rules that the CFPB has thus far issued, we believe it would only be appropriate for such a process to be established,” he said.
Becker also reiterated that the CFPB’s array of rulemakings will “significantly alter the mortgage market in unintended ways” and require credit unions to make major investments, incur significant expenses and “rework nearly every aspect of their origination and servicing operations.” With that in mind, the CFPB should use its broad discretionary authority under the Dodd-Frank Act to exempt federally-insured credit unions from its mortgage rules, Becker said.
Credit unions can get helpful information about the CFPB’s mortgage rules, including summaries of the final rules, insightful blog posts, articles, webcasts and more by visiting NAFCU’s CFPB Mortgage Rules webpage. NAFCU is also encouraging credit unions to participate in its ongoing webcast series on the CFPB’s mortgage rules.