The Consumer Financial Protection Bureau's “Know Before You Owe”project to consolidate Truth in Lending and Real Estate Settlement ProceduresAct disclosures is a step in the right direction, said NAFCUPresident/CEO Fred Becker, but conflicting requirements inherent inthe two statutes might make the task impossible.

The problem is that TILA and RESPA disclosures detail two related, but differentsteps in the process: mortgage lending and home purchasing. The proposed consolidation could require credit unions tofill out the RESPA portion of the settlement document, which wouldbe problematic, Becker said in a letter to the agency.

“Most credit unions do not have the existing expertise onstaff to carry out this task,” he said. “Further, given thecomplexity and legal liabilities, this is not the type of job forwhich an existing employee might be easily trained.”