June 28, 2019

NAFCU shares CUs' TRID concerns with CFPB

CFPBAs the CFPB prepares to review its TILA/RESPA integrated disclosure (TRID) rule, NAFCU met with the bureau to discuss the costs and benefits of implementing the rule, as well as credit unions' concerns and recommendations for more guidance. TRID was among credit unions' top compliance issues last year.

The Dodd-Frank Act requires the bureau to review significant rules every five years. It plans to complete its assessment of the TRID rule in the fall of 2020 and is seeking stakeholder input to help inform its assessment process.

Earlier this year, the bureau released compliance guidance on TRID. NAFCU requested more clarity and assistance for credit unions on: cure provisions and error corrections, negative owner's title insurance premium, calculating cash to close, second lien loans, pre-approvals/pre-qualifications and payoff in a purchase money loan. The association continues to work with the bureau on these issues.

In addition to the difficulties and misunderstandings credit unions face when complying with TRID, NAFCU and the bureau discussed credit union lending market trends and areas to focus on during the rule's assessment.

NAFCU Vice President of Regulatory Compliance Brandy Bruyere, Director of Regulatory Affairs Ann Kossachev and Senior Regulatory Compliance Counsel Elizabeth LaBerge attended Thursday's meeting.

The bureau recently released FAQs addressing corrected closing disclosures and the three business-day waiting period before consummation, model forms and construction loans. NAFCU has various resources available on TRID.