NAFCU has written the Consumer Financial Protection Bureau to urge the agency toallow credit unions as much time as possible to implement a numberof different housing finance regulations expected to be finalizedin 2013.

“As NAFCU has discussed in our comment letters to the CFPBregarding qualified mortgages, mortgage servicing, high-costmortgage loans, loan originator compensation and appraisal reforms,it is pivotal that the CFPB's final rules in each of the respectiverulemakings provide credit unions ample time to implement theregulations,” wrote Carrie Hunt, NAFCU's general counsel, in a letter to CFPBDirector Richard Cordray.

“Each of these rules is very likely to be burdensomeindependently; however, with all five expected to be issued beforeJan. 21, 2013, credit unions will face unprecedented challenges todigest, understand and implement the regulations,” Hunt's lettersaid.

The association suggested the bureau had two different avenuesfrom which to choose to give credit unions more time to comply withthe new regulations.

“While we understand that Title XIV of the (Dodd-Frank Act)provides a set effective date for the agency's 'qualifiedmortgages,' the CFPB can assert its greater discretionaryrulemaking, examination and supervisory authorities to determinethat 12 months is an inadequate period for financial institutionsto effectively implement the regulations.” she wrote.

Or, NAFCU suggested, the bureau could use its “broad authority”to provide an extended effective date for all credit unions, on thegrounds that they are “small entities.”

NAFCU believes Congress granted the CFPB this authority whendealing with smaller organizations because it understood that anynew rules would have a deeper impact on them than on largercompetitors. “As you consider our request, we also ask that youcontemplate the interplay between the various mortgage rules thatthe agency will be finalizing next month and the mortgagedisclosure rules integrating the Truth-in-Lending Act and RealEstate Settlement Procedures Act (RESPA) disclosure forms,” Huntadded.

“The agency has indicated that it will likely issue a final ruleon the combined mortgage disclosures in the summer of 2013. Thus,it would be helpful to credit unions, and ultimately their 94million members, if the CFPB delays the determination of theeffective dates of the mortgage rules due in January until itfinalizes the combined mortgage disclosure rules,” Hunt's lettersaid.