Summary outlines ‘Alert’ on CFBP Reg Z amendments
Sept. 6, 2016 -- A summary of NCUA’s recent “Regulatory Alert” about three final CFPB rules amending Regulation Z (Truth in Lending) has been published and posted by NASCUS (available to members only).
The May NCUA Alert noted that the CFPB amendments applied to credit unions which originate or service closed-end mortgages secured by a dwelling, including small creditors operating in rural or underserved areas. “Taken together, the changes made by these final rules may give you more flexibility in complying with applicable standards by making it more likely your credit union can be considered to be a small creditor or to be operating in a rural or underserved area,” the NCUA Alert states. “The one exception is a provision requiring you to count the assets of an affiliate originating covered mortgages toward the asset threshold for small creditor status.”
The agency alert (16-RA-05) includes two enclosures: charts of changes relating to small creditors and rural or underserved areas under TILA, and; a summary fo changes relating to small creditors and rural or underserved areas under TILA.