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NAFCU Regulatory Affairs Counsel Alexander Monterrubio on Tuesday welcomed the Department of Housing and Urban Development's proposed revisions to its "Addendum to Uniform Residential Loan Application" in a letter to the agency yesterday.

The addendum (Form 92900-A) is filled out by lenders and used by the Federal Housing Administration to determine the eligibility of the borrower and proposed transaction. In Tuesday's comment letter, Monterrubio said the suggested changes "would render the form more efficient and practical for both lenders and borrowers."

Some of the proposed revisions include:

• eliminating references to outdated handbooks;
• updating the form to include the most current non-discrimination language;
• differentiating between the initial and final Uniform Residential Loan Applications; and
• replacing outdated language regarding acceptable sources of funds.

Although NAFCU supports these revisions, Monterrubio urged HUD keep in mind the impending effective date of CFPB's Truth in Lending Act and Real Estate Settlement Procedures Act integrated disclosure (TRID) rule (now slated to take effect on Oct. 3). He urged sufficient time for credit unions to implement the revised form.

"HUD's effort to provide clear guidelines coupled with an implementation date consistent with the TRID rule will afford credit unions the opportunity to work with borrowers in a way that minimizes confusion and the already overwhelming regulatory burden on credit unions," Monterrubio said.