MCUA Comments on CFPB's Mortgage Servicing Proposed Rules
The Missouri Credit Union Association (MCUA) submitted two separate formal comment letters on the CFPB’s mortgage servicing proposed rules. In our letters, we urged the Bureau to consider that many of the proposal requirements are outside of the statutory requirements under the Dodd-Frank Act. We also urged the Bureau to exempt credit unions from several provisions within the proposed rules, where possible. The Dodd-Frank Act requires that these mortgage servicing rules be finalized by the CFPB not later than January 21, 2013, and we stressed to the agency that credit unions will need a lengthy period of time to prepare to comply with the rules’ requirements, and we urged the Bureau to allow at least 18-24 months for compliance.