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Michigan Credit Union League

MCUL Seeks to Delay Integrated Mortgage Disclosure Rule

MCUL & Affiliates is pushing to delay the effective date of the integrated mortgage disclosure rule until the end of the year to allow for better implementation and more clarification.

MCUL filed a comment letter with the Consumer Financial Protection Bureau addressing its concerns.

Under the proposed rule, the CFPB seeks to delay the effective date of the integrated mortgage disclosure rule from Aug. 1, to Oct. 3, to allow for better implementation and consumer adjustment.

MCUL advocated for a safe harbor period under the proposed rulemaking until the end of the year and sought further clarification and guidance from the CFPB addressing whether credit unions that were ready to begin utilizing their forms on the initial effective date of Aug. 1, could begin doing so on Aug. 15, or alternatively, begin doing so on Oct. 3.

MCUL also sought further clarification regarding the applicability of the proposed rule with regards to entities that generated five or fewer mortgages in a year. The CFPB’s small entity guide indicated that creditors originating five or fewer mortgages in a year were exempt from the proposed rule. However, the CFPB updated its small entity guide in June 2015 and it no longer states that creditors generating five or fewer mortgages are exempt.

MCUL in conjunction with CUNA has requested that the CFPB provide guidance stating the proposed rule will not cover credit unions making five or fewer mortgages in a year.

MCUL will continue to monitor this proposed rule and will communicate further developments. If you have any questions or comments, please contact MaryJo White at MaryJo.White@mcul.org or Sarah Stevenson at Sarah.Stevenson@mcul.org.

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2015-07-20 00:00:00