With one comment period closing and another beginning, credit union trade groups are largely receptive to potential changes to Call Reports and TRID compliance rules.
Monday, Aug. 15 marks the end of the extended comment period regarding the National Credit Union Administration’s Request for Information (RFI) regarding its Call Report Modernization efforts, an attempt to make "data systems better and more efficient," according to the regulator. The original deadline for the RFI was Aug. 1, but it was extended at the request of trade groups due to conflicts with credit unions filing their current call reports around that time, and comments will be accepted until the end of the month.
The two major credit union trade groups’ comments reflected a generally positive attitude toward NCUA’s efforts.
"[We hope] the project will reduce overall regulatory burden through the use of enhanced technology and finding efficiencies," said Andy Price, senior director of advocacy at the Credit Union National Association. In its comment letter, CUNA requested the regulator make the reporting more "intuitive," while only collecting relevant data and removing data that does not have supervisory purpose.
The National Association of Federal Credit Unions has also expressed optimism for the possibilities of a modernized Call Report.
Michael Emancipator, NAFCU’s Senior Regulatory Affairs Counsel Michael Emancipator, supported the NCUA’s "overall enterprise solution modernization program," and also the form 4501A profile.
"An updated Call Report could provide NCUA with a more accurate picture of individual credit union health," Emancipator said. "This would enable NCUA examiners to conduct more thorough pre-exam reviews, and thus decrease the amount of time spent on-site, or at least decrease the amount of examiner-requested documentation," he added.
According to NAFCU, the number of Call Report items has more than doubled since 2008. Emancipator requested that the NCUA remove lines unrelated to a credit union’s overall financial health while also overhauling the data entry and submission procedures. Additionally, NAFCU had requested a call-in number for CUS to seek support when completing call reports.
TRID Public Comment Request Posted
A comment period also opens this week for public input on the federal register regarding changes to the Truth in Lending Act-Real Estate Settlement Procedures Act Integrated Disclosure (TRID).
The Consumer Financial Protection Bureau posted a public comment request regarding proposed amendments to the Real Estate Settlement Procedures Act and the Truth in Lending Act. The CFPB is also proposing additional items, including "tolerance provisions for the total of payments, an adjustment to a partial exemption mainly affecting housing finance agencies and nonprofits, extension of coverage of the integrated disclosure requirements to all cooperative units, and guidance on sharing the disclosures with various parties involved in the mortgage origination process," according to the Federal Register request. The comment period closes on Oct. 18.
According to NAFCU, the proposal, released last month, reflects many changes sought after by the association, such as codification of the bureau’s informal compliance guidance and clear guidance regarding construction lending. NAFCU had also requested the Bureau address "several ambiguities in the TRID rule." Those ambiguities include the inability to provide revised loan estimate after providing the closing disclosure, calculation issues involving owner’s title insurance premiums, construction loan concerns and insufficiency of sample forms.
CUNA also expressed satisfaction with the proposed TRID changes, with President/CEO Jim Nussle thanking CFPB Director Richard Cordray "for proposing these changes that we believe should be, overall, helpful to credits unions by adjusting some of the issues we pointed out with the initial disclosure rule that went into effect last Oct. 3."
CUNA’s specific requests addressed by the Bureau included:
- Creating tolerance provisions for total payments that "parallel existing tolerances for the finance charge and disclosures affected by the finance charge"
- Extending TRID coverage to include all co-op units
- Uniform rules regarding integrated mortgage disclosure requirements for co-ops
- Disclosure sharing guidance in the mortgage origination process.
The trade association continues to analyze the proposal but said it has seen positive changes in construction loans, affiliate charges, lender and seller credits, model forms, escrow account disclosures and other provisions.
