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NAFCU will soon publish a Regulatory Alert seeking members' input on CFPB's proposed updates to its Truth in Lending Act/Real Estate Settlement Procedures Act integrated mortgage disclosure rule, published in today's Federal Register. NAFCU is focused on making this problematic rule workable for credit unions.

As the only credit union trade to oppose any CFPB authority over credit unions, NAFCU has long pressed the bureau to improve the TRID rule and related guidance. It sees this proposal as a first step in addressing the numerous compliance issues credit unions have experienced during implementation. The proposal is out for comment until Oct. 18.

CFPB's proposal, released in July, incorporates several NAFCU-sought changes, including recommendations on the codification of the bureau's informal compliance guidance and more guidance on construction lending. Other changes 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 pressed CFPB to address several ambiguities in the TRID rule, including: 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 information on the proposed changes is available in a recent NAFCU Compliance Blog post.