CUNA is formally asking the CFPB to provide a temporary safe harbor from the enforcement of integrated disclosure requirements for mortgage loan transactions under the bureau’s TILA-RESPA Integrated Disclosures (TRID) regulation.
In a comment letter to the bureau signed by Andrew Price, senior director of advocacy and counsel, CUNA stated that the trade association appreciates the CFPB extending the effective date to Oct. 3, 2015.
“CUNA believes the additional two-month period is a step in the right direction to allow for an orderly transition to the new regulatory regime,” wrote Price. “In particular, the extension is welcome given that the current effective date falls during the summer months which is the busiest time of the year for many credit unions.”
But Price noted that CUNA continues its ongoing call to implement a safe harbor for legal liability and enforcement until the end of the year to allow for proper transition to the new regulatory regime.
“We believe this is appropriate given the magnitude of changes requested by the CFPB,” Price wrote.
Price added that many credit unions will need to “run dual tracks during the transition to provide for those loans whose applications are received before the effective date versus those received after the effective date as provided in the rule. Allowing the industry ample time to properly plan for compliance with this major rule will be crucial to ensure proper implementation. This transition will be cumbersome for most, so any additional time will greatly benefit the industry, minimize costs, and provide a smooth transition to the new regulatory regime.”