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CFPB Responds to Concerns about Implementing TILA¬/RESPA

Fri, Jun 12, 2015

Washington, District Of Columbia

CUNA has engaged in robust advocacy efforts on behalf of our members regarding the new TILA­/RESPA mortgage disclosure and timing rules that go into effect on August 1, 2015. In particular, CUNA urged the CFPB in meetings and in writing to provide a “hold­harmless” period for compliance and liability on the new rules until January 2016, for credit unions that make good faith efforts to comply. CUNA and other trade associations sent a letter to the CFPB on this matter in March 2015. CUNA also urged Members of Congress to encourage the CFPB to provide this “hold ­harmless” period. It supported legislation, H.R. 2113, which would allow industry stakeholders to make good faith efforts with compliance with the new rules until the end of the year without fear of enforcement actions or lawsuits. To write directly to regulators use On June 3, the CFPB responded to these concerns by stating it will be “sensitive to the progress” made by industry that have made good faith efforts to comply with the rules on time. The CFPB did not expressly provide a grace period or hold ­harmless period for compliance and liability until the end of the year. As such, CUNA will continue to advocate to the CFPB that more unambiguous relief is necessary, and we will also continue to push legislation for this change.