Only About Half of CUs Say They Are Ready For New TILA/RESPA Disclosure Rules

ARLINGTON, Va.—Nearly half of CUs polled in a new survey indicate they are ready for the CFPB’s Truth in Lending Act and Real Estate Settlement Procedures Act (TILA/RESPA) integrated disclosure rules that go into effect next month.

Forty-four percent of survey respondents in NAFCU’s September Economic & CU Monitor sated they were “very confident” they were prepared, while 38.9% said they were “mostly confident.” The remaining 16.7% were “somewhat confident.”

The September Economic & CU Monitor featured results of a special-topic survey on credit unions’ regulatory burden. Highlights are:

  • Nearly one-third of survey respondents (31.6%) said their member business lending programs have been stifled by regulatory burden.
  • In July the Department of Defense finalized amendments related to the Military Lending Act (MLA), requiring lenders to identify whether borrowers are covered by the rule on extensions of consumer credit. Lenders can query the MLA database or a consumer report from a nationwide consumer reporting agency. “Giving credence to NAFCU’s contention that the MLA database may be unreliable,” NAFCU stated that only 18.2% of respondents said that they would use it exclusively, as opposed to 45.5% who said they would use reporting agencies exclusively and 36.4% who expect to use both.
  • The FCC recently issued an order intended to provide clarity on changes to the Telephone Consumer Protection Act. The changes could potentially impact credit unions in areas beyond those that the rule is intended to address. When asked about the circumstances under which they contact their members by phone or text, the most common response was for marketing or sales, but member notification and fraud prevention were important uses, survey respondents said the reasons they contact their members by phone or text are for account alerts (35.3%), identity theft protection (29.4%) and data breach notification (23.5%).

The monthly survey also looked at CU performance and the economy. Highlights are:

  • Credit unions’ member and loan growth are at their highest levels in a decade, with the latter driven by a 15% surge in vehicle loans versus last year.
  • A strong dollar and low commodity prices are placing downward pressure on inflation. This leaves the Federal Reserve with a difficult decision this month on whether to increase the federal funds rate target.
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