Compliance Blog

Written by Steve Van Beek

It has been almost a month since the CFPB started finalizing their new mortgage rules.  And, credit unions still don't have a full picture of what Regulation Z and Regulation X will look like come January 2014.  

I blogged about this issue back in September 2012 - when credit unions were trying to understand the proposals and how they would impact their credit union:

"The response in the joint letter is to strongly request that the CFPB publish a complete version of Regulation Z (i.e., as the regulation would be if all the proposals were adopted):

'Finally, there are several outstanding proposed rules making changes to Regulation Z.  These proposals cross-reference provisions in each other, making it difficult to tell what each references and what Regulation Z would look like if all of these proposals are finalized.  In addition, there are conflicts among the proposals.  For example, the proposed Ability to Repay rule would remove § 1026.35 because Dodd-Frank made it obsolete, but the proposed HOEPA rule would retain it.  We respectfully request that the CFPB publish a single version of Regulation Z as it would be amended by all of the pending rulemakings as soon as possible.  This would improve our ability to provide input that CFPB will need before the comment periods close.'

I don't think it is too much to ask that the CFPB provide a complete version of the proposed Regulation Z.  Only with a complete version will credit unions be able to analyze and review the all the proposed changes together and provide substantive comments to the CFPB about how the proposals will impact their mortgage operations."  

The CFPB never did provide a full Regulation Z or Regulation X of the proposed rules.  

Now, that the rules are finalized - the CFPB needs to take steps to help credit unions understand the new regulations.  Considering there are seven inter-related new regulations, it would be extremely helpful if the CFPB put together a full Regulation Z and Regulation X - as they will look in January 2014 - so that credit unions can see the total picture rather than having to review the requirements piecemeal through each of the final rules.  Hopefully the CFPB is listening this time.

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NAFCU Webcast on Final Rules.  The first webcast of our Mortgage Reform Series will be Wednesday, February 13 on The CFPB's Final Mortgage Regulations.  Registration is still open and, as always, you don't have to be a NAFCU member to participate.  In fact, you don't even have to be a credit union.  Our conferences and webcasts are open to everyone.