The CUNA comment letters to the Consumer Financial Protection Bureau (CFPB) address proposed amendments to Regulation Z, which implements the Truth in Lending Act (TILA), and Regulation X, which implements the Real Estate Settlement Procedures Act (RESPA). The regulations would coordinate with changes proposed in connection with the combined TILA and RESPA forms that will be provided for most closed-end mortgage loans.
The mortgage forms and proposed rules are scheduled to be finalized by January.
"CUNA strongly opposes application of many aspects of the Regulation Z and Regulation X proposals to credit unions," CUNA Senior Assistant General Counsel Jared Ihrig wrote in the letters. "Credit unions do not seek to mislead their members or take advantage of them in the mortgage servicing process, and credit unions already comply with a number of regulations designed to protect consumers from abuses in this area," he added.
The CUNA comment letters noted that many of the provisions in the proposals would impose significant, burdensome requirements on credit unions. Further, CUNA pointed out, many of the provisions that would be imposed on credit unions are not required by statute--and CUNA will not support them.
Ihrig also wrote that CUNA has also concluded that several provisions in the proposal are overly broad and will have a detrimental impact on credit unions. This was not the intent of the Dodd-Frank Wall Street Reform Act, he said. Rather, he said, it appeared that the burdensome regulatory requirements would only apply those that engage in unfair and deceptive acts and practices against consumers.