WASHINGTON (9/23/13)--Credit unions need to take the time to complete a compliance survey on the 2014 Consumer Financial Protection Bureau's mortgage lending rules, urges Kathy Thompson, Credit Union National Association senior vice president for compliance and legislative analysis, to aid the trade group in assessing the full impact on credit unions of the new CFPB rules.
"We really need you to provide some input in this CUNA survey--and we've moved the response date from Sept. 23 to Sept. 27--this Friday--to give you time to weigh in," Thompson said in CUNA's CompBlog
Friday. Moreover, if a credit union only can fill in parts of the survey, Thompson suggests which questions are most important to CUNA.
"In words it uses regularly, the CFPB is a 'data-driven' agency, so please give us data that might help us to persuade the agency to postpone the 'compliance date' of the mortgage regs," Thompson urged.
While the agency will be unlikely to move the January 2014 "effective dates" of the mass of new regulations, Thompson explained that the Federal Reserve Board, which formerly regulated the consumer protection laws now under the CFPB's jurisdiction, often authorized a later "compliance date" in recognition of the practical operational considerations to comply.
Thompson said the more information a credit union can provide on the survey, the better, but she asked respondents at least to answer the following questions:
Number 8: Are you relying on a vendor to help with compliance?
Number 9: If so, when do you expect your vendor to provide all of the necessary changes?
Number 10: After your vendor has made the necessary changes, how long will your credit union need to test and implement the changes?
Number 11: How long will your credit union need to train staff on the vendor's changes?
Number 15: What is your credit union's asset size?
CFPB Director Richard Cordray earlier this month said that the bureau "will be sensitive to...good faith efforts to come into substantial compliance" by January 2014.
At CUNA's Compliance School last week, the NCUA said that the agency will start looking at how compliance is coming along after the regulations go into effect, but won't start writing up credit unions up until "summertime." Thompson says the better approach than a vague "good faith effort" is for the CFPB to declare a formal "compliance date" next fall.
Use the resource link below to access the CUNA survey and to read Thompson's CompBlog