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CUNA Uncovers Discrepancy in CFPB's TRID Implementation
Monday, June 29, 2015 6:40 AM

Credit Union National Association uncovered and revealed a discrepancy with huge implications for more than 700 credit unions (those that originate five or fewer closed end real estate loans but more than 25 total loans a year) in the Bureau's proposal to move the enforcement date for TILA/RESPA rules to Oct 3.

In the weekly Nussle Report, CUNA President and CEO Jim Nussle writes, "In our examination of Bureau paperwork, we found a difference between the CFPB's previous TILA-RESPA Small Entity Compliance Guide compared with text in the latest Small Entity Compliance Guide and the final rule text. We have asked CFPB to clarify the inconsistency and ensure that credit unions that make five or fewer mortgages in a calendar year are exempt from the Know Before You Owe rule, which includes TILA/RESPA."

Nussle says earlier versions of the documents exempted these credit unions while the current version omits the exemption except for credit unions that also make fewer than 25 total loans.