Members’ input sought on TISA disclosures, QRM
Sept. 17, 2013 – NAFCU is looking for members’ input soon on an NCUA proposal regarding a periodic reinstatement of an information collection related to the Truth in Savings Act and an interagency proposal to align the definition of “qualified residential mortgage” with the definition of “qualified mortgage” under CFPB regulations.
The deadline to submit comments to NAFCU on TISA disclosures is Sept. 27, and the deadline to submit on the QRM proposal is Oct. 2.
The NCUA proposal on TISA is a reinstatement of a current information collection that would require credit unions to carry out TISA consumer disclosures on interest rates, bonuses and fees associated with their share deposit accounts and related services. Under the act, NCUA is required to set rules substantially similar to those issued by the CFPB, taking into account the nature of credit unions. Credit unions must retain evidence of compliance for two years after the disclosures are required.
The QRM proposal was issued in late August by the FDIC, the FHFA, the Federal Reserve Board, the Department of Housing and Development, the Securities and Exchange Commission, and the Office of the Comptroller of the Currency; the proposal makes the definition of “qualified residential mortgages” consistent with that of the CFPB’s for “qualified mortgages” – a change NAFCU has specifically requested.
The QRM proposal also requires securitizers to keep a stake in mortgages with less than 30 percent down payment. Like “qualified mortgages,” a QRM may not have a debt-to-income ratio exceeding 43 percent. However, unlike the CFPB’s rule, a GSE-eligible loan would not be a QRM.
Members may submit comments on either proposal on the NAFCU website.
Interagency proposal on QRM
NCUA proposal on TISA