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NAFCU will meet throughout the week on key credit union issues, including unfair, deceptive or abusive acts or practices (UDAAP), TILA-RESPA integrated disclosure (TRID) rule and debt collection practices.

UDAAP

Today, NAFCU Director of Regulatory Affairs Ann Kossachev and Regulatory Affairs Counsel Kaley Schafer will attend the CFPB's symposium focused on the "abusive" prong of UDAAP. NAFCU has long advocated for the bureau to issue specific guidance on prohibited practices so financial institutions have more clarity on this issue. Last year, NAFCU again asked the bureau to provide guidance to clarify the UDAAP standard.

The symposium is set to begin at 9 a.m. Eastern. Those interested in attending in person can register here; a livestream will also be available. Following the symposium, NAFCU will provide an update on its member-only Compliance Network. This is the first in a series of symposia hosted by the CFPB; see the other topics here.

TRID

Following NAFCU's request earlier this year for more TRID FAQs, Kossachev, NAFCU Vice President of Regulatory Compliance Brandy Bruyere and Senior Regulatory Compliance Counsel Elizabeth LaBerge will meet Thursday with the CFPB to discuss additional opportunities for direction.

The bureau's first FAQ covers questions related to:

• corrected closing disclosures and the three business-day waiting period before consummation;
• model forms; and
• construction loans.

NAFCU requested more clarity and assistance for credit unions on: cure provisions and error corrections, negative owner’s title insurance premium, calculating cash to close, second lien loans, pre-approvals/pre-qualifications and payoff in a purchase money loan.

Debt Collection

Schafer tomorrow will attend a roundtable at the Small Business Administration (SBA) to discuss debt collection practices. The CFPB issued a proposed rulemaking on third-party debt collection in May, and a rulemaking related to first-party debt collection remains a possibility. The roundtable will also consider the Federal Trade Commission's (FTC) safeguards rule proposal.

NAFCU previously urged the bureau to exempt credit unions from any rules related to first- and third-party debt collection, as credit unions are not the bad actors in this space.