ALEXANDRIA, Va.–NCUA is reminding that credit unions have until July 7 to comment on the Consumer Financial Protection Bureau’s proposal to delay the effective date of a significant mortgage disclosure regulation.
The CFPB has proposed to make the final rule effective Oct. 3, 2015, instead of the original date of Aug. 1 and then the originally proposed Oct. 1. extension, which falls on a Saturday. The proposal to extend the effective date is expected to be published in the Federal Register soon.
Separately, Sept. 22 is the deadline for comments on NCUA’s review of its rules related to corporate CUs, money laundering and credit union directors, officers and employees. The review of the regulations is required by the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA).
“These new mortgage disclosure requirements have important consequences for credit unions and their members,” said NCUA Chairman Debbie Matz. “Credit unions have an opportunity to voice their views on the timeline for rolling out the new disclosures. Credit unions may need time to perform conclusive testing and work with technology vendors on the TILA-RESPA mortgage disclosure systems. They can provide CFPB with valuable, practical information about their experiences preparing to issue the new disclosures and their implementation concerns.”
The Dodd-Frank Wall Street Reform and Consumer Protection Act directed the CFPB to integrate mortgage disclosure requirements under the Truth in Lending Act and the Real Estate Settlement Procedures Act. CFPB issued a final rule known both as the TILA-RESPA Integrated Disclosure Rule and the Know Before You Owe Mortgage Disclosure Rule. The final rule combines existing mortgage disclosure requirements, implements new mortgage disclosure requirements and refines existing disclosure requirements for both mortgage and non-mortgage loans.
“When the rule becomes effective, NCUA examiners will look for reasonable and good-faith efforts by credit unions towards substantial compliance with the final rule,” Matz said.
The credit union trade groups have continued to press the agency to provide a safe harbor period through Dec. 31 in order to protect credit unions and other financial institutions from liability under enforcement of the new rule as they acclimate to the new TRID requirements. The rule requires updated forms that lay out the terms of a mortgage for the borrower.