January 21, 2020

NAFCU recommends areas for CFPB to review under TRID

CFPBAs the CFPB prepares for its assessment of the Truth in Lending Act (TILA)/Real Estate Settlement Procedures Act (RESPA) integrated disclosures (TRID) rule, NAFCU's Kaley Schafer urged the bureau to carefully consider the rule's impact – including associated compliance costs, the ability to sell to the secondary market, and products offered.

Schafer, NAFCU's regulatory compliance counsel, sent the letter in response to a request for information on the CFPB's proposed approach to the assessment.

In addition, Schafer reiterated NAFCU’s call for additional guidance from the CFPB on outstanding TRID issues such as cure provisions and error corrections, negative owner’s title premium, calculating cash to close, second lien loans, pre-approvals, payoffs on a purchase money loan, and a consumer’s ability to waive the waiting period.

NAFCU met with the bureau early last year to discuss the costs and benefits of implementing the rule, as well as credit unions' concerns and recommendations for more guidance. NAFCU often seeks credit union feedback on issues and shared results from a survey on this topic in the letter.

NAFCU members appreciate the additional FAQs provided by the Bureau since implementation; however, additional guidance is necessary,” wrote Schafer. “In a recent survey, 75 percent of respondents reported that TRID guidance provided to date has not been helpful. Thus, NAFCU members are left seeking out additional compliance assistance incurring additional costs.”

NAFCU previously requested more clarity and assistance for credit unions on these issues and will continue to work with the bureau. NAFCU has various resources available on TRID.