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CUNA is asking the CFPB for answers about a discrepancy regarding TILA-RESPA rules, and as a result is urging the agency to exempt credit unions that make five or fewer mortgages per calendar year from the Know Before You Owe rule.
In a letter Friday to Bureau Director Richard Cordray, CUNA President and CEO Jim Nussle said the trade association found a discrepancy between the CFPB’s previous TILA-RESPA Small Entity Compliance Guide and supplementary information to the TRID rule compared with text in the latest Small Entity Compliance Guide and the final rule text.
“At its core, this is an issue of transparency,” said Nussle. “The CFPB made a change to the Small Entity Compliance Guide that will affect over 700 credit unions and numerous other financial institutions, but did not highlight, publicize, or explain this change. Although listed as a ‘miscellaneous administrative change’ by the Bureau, the new rule is a substantial change that may deal a striking blow to anyone making five or fewer mortgages in a calendar year. CUNA urges the CFPB to address our concerns and confirm that creditors making five or fewer mortgages per year, as outlined in the rule’s supplementary information and the September 2014 Small Entity Compliance Guide, are exempt from the TILA-RESPA rule.”
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