ARLINGTON, Va.-In response to a request for comment by NCUA pursuant to the Economic Growth and Regulatory Paperwork Reduction Act, NAFCU outlined a number of changes it would like to see in the category of “Consumer Protection: Lending Related Rules.” NAFCU’s comment letter said they would like to see the elimination of the requirement that federal credit unions request demographic information from telephone, Internet, or mail loan applicants under the Home Mortgage Disclosures Act rules. NAFCU also asked that the previous HMDA reporting requirements for home improvement loans be reinstated. Additionally, NAFCU asked that recent changes to the Equal Credit Opportunity regulations requiring that a joint applicant’s intent be evidenced during the application time and clarifying that signatures on a promissory note does not demonstrate intent. “While NAFCU supports the purpose of Regulation B, which is to promote the availability of credit to all credit applicants without discriminating on a prohibited basis, NAFCU does not believe that this recent rule change furthers this purpose,” NAFCU’s comment letter read. NAFCU also sought statutory changes to amend what is included in annual percentage rate disclosures under the Truth in Lending Act. “Time has shown that a finance charge and annual percentage rate (APR) disclosure that includes certain of the costs associated with receiving credit while excluding others can be very confusing to credit union members. It is very difficult for credit union members to understand why the APR differs from the interest rate and why the amount requested differs from the amount financed,” NAFCU wrote. The trade association also argued that language in the Federal Credit Union Act regarding revisiting the usury rate ceiling every 18 months be changed. NAFCU said the restriction should be removed and authority be delegated to NCUA. NCUA and the other federal financial institution regulatory agencies will put out one or more categories of regulations every six months from 2003 to 2006 to satisfy EGRPRA’s review requirements.

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