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NAFCU and 15 other financial trade associations asked CFPB for a "grace period" or "restrained enforcement and liability" for institutions complying in good faith with the Truth in Lending Act/Real Estate Settlement Procedures Act integrated mortgage disclosures rule after Aug. 1, the effective date, through year-end.

The trades also asked for "authoritative written guidance to complete implementation" on the new rule, a move that would ease the regulatory burden of the rule change.

The groups said that despite having 21 months to prepare for the changes, those subject to this "uniquely complex regulation" won't fully grasp how to properly implement it and comply until guidance is provided and they log some experience with the new forms and processes.

"While you have indicated that the CFPB would not act unreasonably on August 2,," they wrote "there is no opportunity under this regulation to comply early, which means that industry will not be able to test systems, in real-time, in real circumstances, until after August 1."

Among those signing the letter were American Bankers Association, the community Mortgage Lenders of America, CUNA, the Independent Community Bankers of America, and the National Association of REALTORS.

Last week, NAFCU President and CEO Dan Berger on Friday asked NCUA Board members to consider credit unions' "good faith efforts" to comply with the rule.

NCUA has taken this kind of approach before: Berger recalled the agency considered credit unions' "good faith efforts toward substantial compliance" in the early days of CFPB's ability-to-repay, qualified mortgage and mortgage servicing rules in 2014.

NAFCU's regulatory compliance team has put together a compendium of resources on CFPB's mortgage rules, including the TILA-RESPA integrated mortgage disclosure rule, which is available on the association's website.