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March 06, 2015

Berger to NCUA: Focus on 'good faith efforts' on TILA/RESPA

Since CFPB has prohibited early compliance, NAFCU President and CEO Dan Berger on Friday asked NCUA Board members to consider credit unions' "good faith efforts" to comply with the bureau's Truth in Lending Act/Real Estate Settlement Procedures Act integrated mortgage disclosures rule.

"While NAFCU firmly believes that our members have taken the steps necessary to be in compliance as of the August 1, 2015, effective date, we are concerned that credit unions have been restricted in their ability to conclusively test their new platforms for strict compliance with the TILA/RESPA rule," Berger wrote.

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 believes implementing this approach in 2014 resulted in a smoother transition for the mortgage-reform regulations, and we ask that NCUA implement it again for the new integrated mortgage disclosure forms," Berger wrote.

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.