CFPB Roundtable Meeting On TILA/RESPA/HOEPA Proposals
The Consumer Financial Protection Bureau (CFPB) recently held a roundtable meeting to discuss the proposed rule and forms to combine certain disclosures required under the Real Estate Settlement Procedures Act (RESPA) with disclosures required under the Truth in Lending Act (TILA), as well as the proposed rule to implement recent changes to the Home Ownership and Equity Protection Act (HOEPA). At the meeting, participants shared their concerns and questions on the proposed rules with CFPB staff attorneys. Sherry Joseph, Chief Compliance Manager from SECU Credit Union, participated in the meeting and shared concerns from her credit union on the proposed threshold triggers and potential impact on the availability of credit under the HOEPA proposal, as well as concerns with the TILA/RESPA proposal, including the revised definition of "application" and compliance costs associated with the proposed machine-readable record retention requirements.
The Credit Union National Association continues to urge the CFPB to minimize the compliance costs and impact of these proposed mortgage rules and continues to work closely with the CFPB in all aspects related to these and other mortgage rulemakings required by the Dodd-Frank Act.