ALEXANDRIA, Va.—NAFCU President and CEO Dan Berger applauded NCUA Chairman Debbie Matz’s response to the trade association’s request that NCUA consider good faith efforts by credit unions to comply with the CFPB’s new integrated mortgage disclosure forms.
The forms are set to become effective Aug. 1 under the Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA).
“We appreciate Chairman Matz’s exceptional leadership on this issue. She is the first regulator to acknowledge the extraordinary value of recognizing ‘good faith efforts’ by credit unions on this complex new rule, as NAFCU had urged in our letter,” said Berger. “This will go a long way toward ensuring as smooth a transition as possible for credit unions to the new TILA/RESPA mortgage disclosure systems.”
Berger wrote Matz earlier this month recalling the agency considered credit unions’ “good faith efforts toward substantial compliance” in the early days of CFPB’s ability-to-repay, qualified mortgage and mortgage servicing rules in 2014, and asked that NCUA implement a similar examination approach with the new TILA/RESPA integrated mortgage disclosure forms.
In her letter, Matz responded, “NCUA examiners will be looking for reasonable and good faith efforts by credit unions toward substantial compliance with the new rule as of the effective date. NCUA recognizes that some credit unions may need time to perform conclusive system testing and work with their technology vendors to resolve any remaining issues that may occur from extensive testing and use, once their new TILA/RESPA mortgage disclosure systems become fully operational on August 1.”
“We will reassure credit unions that for consistency, NCUA will take the same examination approach as we have with prior CFPB rules,” continued Matz.
NAFCU, with other trade groups, has made a similar request to the CFPB for a restrained examination period