Mary Mitchell Dunn, senior vice president and deputy general counsel of CUNA, sent a letter to the CFPB that asked the bureau to consider simplifying the mortgage application process so it would better serve lenders and borrowers.
‘Regulation Z is one of the most complex and costly regulations to implement for credit unions, and it is at the top of the list for most of our members in terms of rules that need to be simplified,’ Dunn wrote. ‘To that end, CUNA, working with our Consumer Protection Subcommittee and our Lending Council, is undertaking a review of Regulation Z, and we hope to provide additional comments and recommendations to the Bureau by this summer at the conclusion of that review.’
Dunn is also seeking clarification on several aspects of the regulation, particularly its 14-day advance notice requirements and the sections regarding increased penalty rates for delinquent accounts. Dunn also requested that the bureau examine the lending products covered by Regulation Z in order to determine whether they can assist consumers in understanding the content of the loans.