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In a move urged by NAFCU, CFPB on Friday proposed updates to its Truth in Lending Act/Real Estate Settlement Procedures Act integrated mortgage disclosure rule, including more guidance on construction lending, but association President and CEO Dan Berger says it's not enough.

Comments on the changes are due Oct. 18.

"NAFCU appreciates the CFPB revisiting the TRID rule and, at first glance, there appear to be a few positive components that we strongly advocated for on behalf of our members," said NAFCU President and CEO Dan Berger. "Most notably, the bureau has taken our advice regarding the codification of its informal compliance guidance.

"However, the bureau has not gone nearly far enough to address the numerous substantive compliance issues that have been highlighted by credit unions. Although our compliance experts will continue to analyze the proposal to identify its full impact, NAFCU believes this should be the first step in a process to create a mortgage disclosure rule that is workable for financial institutions and benefits consumers."

Other proposed changes to the rule include:

• allowing a revised closing disclosure to reset tolerances under the same circumstances that the current rule permits credit unions to issue a revised loan estimate;
• incorporating informal guidance into the rule;
• clarifying that recording fees and transfer taxes may be charged in connection with housing assistance lending transactions without losing eligibility for the existing partial exemption;
• extending the rule's coverage to include all cooperative units rather than just transactions secured by real property; and
• clarifying how a creditor may provide separate disclosure forms to the consumer and the seller.

NAFCU has been pressing the bureau to address various ambiguities throughout the TRID rule. Among NAFCU's concerns: the inability to provide a revised loan estimate after providing the closing disclosure, calculation issues involving owner's title insurance premiums, construction loan concerns and insufficiency of sample forms, among other things.

More on this topic can be read in today's post to the NAFCU Compliance Blog.