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| Mortgage Lending Relief would provide more Access to Credit |
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In advance of today’s comment deadline on a CFPB request for information, America’s Credit Unions signed onto a joint letter to the CFPB Friday. The request is in response to a March Executive order specifically seeking credit union feedback on ways to promote access to mortgage credit.
The comment letter encourages the CFPB to:
• Re-evaluate and revise the Truth in Lending Act-Real Estate Settlement Procedures Act integrated disclosure (TRID) tolerance provisions, as the complexity of the tolerance requirements frequently results in substantial compliance costs that provide little corresponding consumer benefit;
• Amend the definition of "Application" under TRID, specifically broadening it to include the six data points plus additional information the creditor may reasonably need to make a credit decision; and
• Clarify and expand the definition of "Bona Fide Personal Financial Emergency," including clarifying that the standard includes real-world financial harms such as imminent loss of earnest money, expiring rate locks, firm relocation or occupancy deadlines, contractual penalties, and cascading settlement delays.
A standalone comment letter from America’s Credit Unions is being submitted today.
Credit unions are also encouraged to submit their own comments by today’s deadline. America’s Credit Unions issued a Regulatory Comment alert with information on the request for information and how to submit comments.
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