Compliance Blog

Written by Angela Meyster, Regulatory Affairs Counsel

As the deadline (August 1, 2015 to be exact) looms for the Truth in Lending Act and Real Estate Settlement Procedures Act integration, compliance folks should be aware of the many tools out there to help them with implementation.  Both the CFPB and NAFCU have developed an array of resources to assist in answering common questions and both entities are looking for ideas of what else could be helpful.

From the CFPB:

Implementation Resources on the CFPB’s Website:

• First and foremost, anyone involved in TILA/RESPA integration should sign up for the CFPB’s TILA/RESPA implementation updates email list by going to this website. An email should come through this listserv every time the CFPB makes a change to the rule or offers new guidance, resources, or programs related to the rule.
• The second CFPB resource credit unions should check for everything and anything TILA/RESPA is the TILA-RESPA Integrated Disclosure rule implementation webpage. On it, you will find:
• A link to the TILA/RESPA rule in full;
• The small entity compliance guide, a plain-language guide to the new rules; and
• Guide to Forms, which provides instructions on completing the Loan Estimate and Closing Disclosure;
• Integrated loan disclosure forms and samples, which include the Loan Estimate and Closing Disclosure forms (available in both English and Spanish) and samples for a few different loan types.
• If you have outstanding questions about application or interpretation and want to speak with a CFPB staff attorney directly, you can email CFPB_reginquiries@cfpb.gov or call its hotline at (202) 435-7700.  Note that the CFPB will not respond in writing and any guidance it provides may not be authoritative.

Fannie Mae and Freddie Mac Data Standards:

Fannie Mae and Freddie Mac have released a common industry dataset, “the Uniform Closing Dataset.”  It is calibrated to the Mortgage Industry Standards Maintenance Organization’s (MISMO) data standards so that credit unions may use it in implementing the TILA/RESPA Closing Disclosure Form.  MISMO is also developing in the near future a dataset for use with the Loan Estimate.

CFPB TILA/RESPA Webinar Series:

The Federal Reserve Board of Governors (the Fed) will host a webinar on frequently asked questions about the TILA/RESPA rule on August 26, 2014 at 2 p.m. Eastern.  Those interested in attending may register here.

The webinar is the second in a series on the rule and will feature speakers from the CFPB who will address specific questions about rule interpretation and implementation.  Future webinars will continue to address specific questions related to the rule. CFPB also plans to continue these webinars past the rule’s implementation deadline.

The Fed held an earlier webinar on June 17, 2014, and provided an overview of the rule, the new disclosures, and answered a few compliance questions.  A recording is available on the CFPB’s website.

NAFCU members can submit questions to me, Regulatory Affairs Counsel Angela Meyster, at ameyster@nafcu.org, to pass on to the CFPB to consider addressing through the webinar series. 

Industry Meetings

The CFPB is currently conducting meetings with industry trade groups to learn what issues credit unions, as well as other financial institutions and industry stakeholders, are struggling with as they begin implementation efforts and what resources the CFPB can release to assist entities in this effort.

From NAFCU:

NAFCU’s awesome compliance team has also put out an abundance of resources, with more to come in the near future. Highlights include:

• All the blog posts written to date on TILA/RESPA integration, with a special focus on breaking down the rule and dissecting its particularly troublesome parts.
• For NAFCU members, three thorough articles on the rule: “Delving into the Closing Disclosure: Requirements, Timing, Delivery and More”, “A Deep Dive into the Loan Estimate Disclosure: Requirements, Timing, and Tolerances”, “TILA/RESPA Integrated Mortgage Disclosure Rule: Overview”.  NAFCU’s compliance team has plans to publish several other articles in the near future.
• NAFCU has also hosted two webcasts: The 7th Rule: Unintended Consequences of the New, “Simplified” Mortgage Disclosures and TILA/RESPA Series: Part 1 – An Overview. NAFCU will host additional webcasts in the coming months.
• Finally, for NAFCU members, a Final Rule Summary of the Rule, and Scope & Applicability Chart: TILA/RESPA Disclosures.

NAFCU continues to seek input from members and nonmembers as to additional resources that would be helpful in implementation or addressing problem areas.

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