Newsroom
NAFCU recommends ways to strengthen trial disclosure application
NAFCU Senior Regulatory Affairs Counsel Aminah Moore Wednesday responded to the CFPB’s request for information (RFI) regarding a trial disclosure application from the Independent Community Bankers of America (ICBA) related to consumer construction and construction-to-permanent loans.
The CFPB in 2019 launched three new policies aimed at promoting innovation and facilitating compliance at financial institutions, including the Trial Disclosure Program (TDP). In a letter to the bureau, Moore noted ICBA submitted an application for a TDP waiver template “that aims to increase the availability of affordable single-close construction-to-permanent loans by proposing an alternative Loan Estimate Disclosure (LE) and Closing Disclosure (CD) that the ICBA believes will more fully disclose all the various components of these types of loans.”
While NAFCU is generally supportive of ICBA’s efforts to reduce closing costs and ensure consumers are adequately informed, Moore offered recommendations to strengthen the waiver application, such as:
- including bullet points to explain why an amount can increase after closing as “this will be helpful for consumers to estimate costs and avoid a surprise increase in payment;”
- having the “Loan Information” section of the CD state the loan term for the construction phase “to” the loan term for the permanent phase – Moore noted “this is a change that was proposed for the LE, and the two documents should state the information as succinctly as possible to provide greater clarity;”
- naming documents that clearly reflect their purpose and are consistent across all documents; and
- providing more detail in the projected payment section of the CD to include the payment calculation for years there is an estimated change in payment.
NAFCU will continue to advocate for ways to provide credit unions with regulatory relief and better serve their 135 million members.
Share This
Related Resources
Add to Calendar 2024-04-15 09:00:00 2024-04-15 09:00:00 Mergers and Acquisitions: Unifying Two Different Executive Total Compensation and Benefits Programs Listen On: Key Takeaways: [03:50] With the merger of a smaller credit union into a larger one you are really only dealing with integrating staff into the larger credit union. [05:53] When working with a merger of equals we start with a deep dive into the executive compensation and benefits of each organization. [09:09] If your current executive benefits provider doesn’t conduct regular plan evaluations, consider having a plan audit anyway. [13:46] Don’t overpay for these things if you don’t have to. When you have more options available that means the cost is more appropriate. [17:11] It is in a unified organization’s best interest to do tier timelines where we look at your top executives who are critical to the unified organization’s success today and then slowly add in the next levels. Web NAFCU digital@nafcu.org America/New_York public
Mergers and Acquisitions: Unifying Two Different Executive Total Compensation and Benefits Programs
preferred partner
Gallagher
Podcast
Add to Calendar 2024-04-11 14:00:00 2024-04-11 14:00:00 Regulation E: Impacts Across Your Institution Dive into regulatory excellence with, Regulation E: Impacts Across Your Institution. This webinar is tailored to empower you with the knowledge and strategies necessary to effectively implement the Electronic Funds Transfer Act (EFTA) and Regulation E within your operations. You’ll explore how to apply Regulation E across various business areas to ensure compliance obligations are met with precision. Key Takeaways Learn the basics of EFTA and Regulation E Understand how to apply Regulation E at your organization to detect processes and transactions that require Regulation E compliance Discover how Regulation E may apply to a large breath of areas in your institutions and functions for which you may rely on third-party vendors Review recent enforcement activity for non-compliance with EFTA and Regulation E Register Now $295 Members | $395 Nonmembers(Additional $50 for USB)One registration gives your entire team access to the live webinar and on-demand recording until April 11, 2025Go to the Online Training Center to access the webinar after purchase » Who Should Attend NCCOs NCRMs Compliance and risk titles Education Credits NCCOs will receive 1.0 CEUs for participating in this webinar NCRMs will recieve 1.0 CEUs for participating in this webinar Web NAFCU digital@nafcu.org America/New_York public
Regulation E: Impacts Across Your Institution
Credits: NCCO, NCRM
Webinar
Refining the Consumer Loan Experience
Credit Unions, Education, Consumer Lending, Growth & Retention, Current Affairs, Marketing
preferred partner
Securian Financial
Blog Post
IRS SECURE 2.0 “Grab Bag” Guidance: Other Issues
Retirement, Credit Unions
preferred partner
Pentegra
Blog Post
Get daily updates.
Subscribe to NAFCU today.