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As sought by NAFCU, CFPB's final regulation combining mortgage disclosures required under the Truth in Lending Act and Real Estate Settlement Procedures Act provides a delayed compliance deadline – Aug. 1, 2015 – and does not set all-inclusive definitions of annual percentage rate and "finance charge."

NAFCU, in its official comment letter on the proposed rule, urged CFPB to give credit unions at least 18 months after the final rule is issued to comply.

CFPB released the full text of its final rule yesterday. NAFCU was also successful in securing changes that mean the rule:

• does not require credit unions to provide total cost of funds of the loans;
• does not add Saturdays to the definition of "business day"; and
• does not require credit unions to keep a machine-readable version of the disclosures.

Currently, credit unions are required to provide two separate early disclosures and two separate closing disclosures; the final rule combines the disclosures into a single statement. Under CFPB's final rule, the new "loan estimate" will have to be delivered to the loan applicant no later than three business days after the creditor receives the loan application. The "closing disclosure" will have to be provided three days before consummation, unless the consumer waives it. The rule greatly restricts the ability of credit unions to change estimated charges and fees.

NAFCU's regulatory affairs staff are studying the final regulation; NAFCU will publish a Final Regulation online with a summary of the rule for its members.

NAFCU Senior Vice President of Government Affairs and General Counsel Carrie Hunt wrote association members with a summary of the rule's implications. "The rule will require your credit union to make significant changes to how it conducts a mortgage transaction," she said, before emphasizing the important changes to the originally proposed rule that were sought by NAFCU.

Hunt also highlighted the requirements for who can provide a "loan estimate," and which charges for services are not allowed to increase.