CFPB's TILA/RESPA Proposed Rule
The Consumer Financial Protection Bureau (CFPB) has issued its proposed rule to formally combine certain disclosures required under both the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA), as required under the Dodd-Frank Wall Street Reform and Consumer Protection Act.
The Credit Union National Association's (CUNA) Regulatory Advocacy staff have developed two separate Comment Calls relating to the proposed rule, the first of which can be accessed here. Comments are due to the CFPB by September 7.
On August 24, CUNA posted a second Comment Call relating to the remainder of the proposed rule, which was just published in the Federal Register on August 23. Comments on the remainder of the proposed rule, which the second Comment Call covers, are due to the CFPB by November 6, 2012. Outside of the proposed new disclosures, the second Comment Call addresses some important proposed changes to the definitions of “application” for purposes of delivering the Loan Estimate, and also to the term “Business Day,” which has caused confusion in credit unions over the past several years as Regulation Z has been amended multiple times.
Credit unions have the opportunity to give input on multiple topics. Due to the magnitude and impact of these proposed changes and the potential effects on mortgage lending going forward, it is extremely important that credit unions share their concerns on this and other proposed rules being issued by the CFPB.