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NAFCU Director of Regulatory Affairs Alexander Monterrubio urged CFPB to set a 24-month implementation period for its mortgage servicing amendments, once that rule is finalized, to give credit unions some breathing room between that date and implementation of the Home Mortgage Disclosure Act rule.

The main implementation date of the HMDA rule is Jan. 1, 2018; Monterrubio noted that an extended implementation period for the mortgage servicing rule would allow credit unions a barrier of at least six months between the two.

"NAFCU and our members remain concerned that the tidal wave of regulations in recent years is altering the financial services market in unintended ways. Every additional rulemaking affecting credit union operations adds to the regulatory burden felt by credit unions as they attempt to come into compliance," Monterrubio wrote. "The Bureau should recognize the substantial costs and resources credit unions are required to expend preparing systems to accurately and effectively come into compliance with these rules and more."

In response to CFPB's request for comment on the rule's provision about periodic statement for borrowers who have filed for bankruptcy, Monterrubio noted NAFCU's belief that the bureau's sampling size for its research could have been larger. He also urged CFPB to develop flexible model statements that can be modified to reflect the appropriate bankruptcy chapter.

Finally, Monterrubio asked CFPB to reconsider the provision about successors-in-interest in its mortgage servicing rule. NAFCU believes the provision would be burdensome and unnecessary. Monterrubio suggested the bureau reopen the provision for additional public comment.

NAFCU also signed on to a joint letter to CFPB on this issue Thursday with the Consumer Mortgage Coalition and CUNA.