NAFCU is seeking members' input on the CFPB's proposed rule to amend requirements under the Truth in Lending Act/Real Estate Settlement Procedures Act integrated disclosure (TRID) rule by Sept. 26.
If finalized, the rule amendments would allow creditors to compare charges paid by or imposed on a consumer to amounts disclosed on a closing disclosure – rather than a loan estimate – to determine if the estimated closing cost was disclosed in good faith. It would also remove the four-business-day limit for providing closing disclosures but, as under the current rule, permit creditors to reset tolerances by providing a closing disclosure within three business days of receiving information sufficient to validate a reason for revision.
"As the only financial services trade to oppose any CFPB authority over credit unions, NAFCU has continuously advocated for the bureau to improve its credit disclosure rules and related guidance," said NAFCU Regulatory Affairs Counsel Ann Kossachev. "This change will hopefully fill gaps that have been created as a result of the current four-business day rule and increase faith in the market."
Comments are due to the CFPB on this proposal by Oct. 10.