WASHINGTON — America’s Credit Unions has joined six other financial services and housing trade groups in urging the Consumer Financial Protection Bureau to make targeted changes to federal mortgage disclosure requirements that the organizations said would reduce compliance burdens while improving the usefulness of disclosures for consumers.
In an Aug. 7 joint letter to the CFPB, the organizations offered three consensus recommendations in response to the bureau’s request for information on promoting access to mortgage credit.
Joining America’s Credit Unions in the letter were the American Bankers Association, American Financial Services Association, Consumer Bankers Association, Housing Policy Council, Manufactured Housing Institute and Mortgage Bankers Association.
Potential Changes to TILA-RESPA
The CFPB is seeking input on potential changes to the TILA-RESPA Integrated Disclosure requirements, commonly known as TRID; rescission rights under the Truth in Lending Act; and reverse mortgage disclosures.
The trade groups said they support the CFPB’s effort to identify targeted reforms that could reduce unnecessary burdens in the mortgage market.
“Our associations represent a broad range of mortgage lenders and financial institutions who collectively agree that several TRID provisions impose substantial operational burden without producing commensurate consumer benefit,” the groups said. “The Bureau can provide meaningful relief through a limited set of practical reforms.”
Three Recommendations
The organizations made three joint recommendations:
Re-evaluate and Revise TRID Tolerance Provisions.
The groups said the existing tolerance framework has become one of the most operationally burdensome elements of TRID compliance.
Although the requirements were intended to provide consumers with firm information about costs, the organizations said their complexity frequently results in substantial compliance expenses with little corresponding benefit to borrowers.
The Real Estate Settlement Procedures Act requires early loan estimates to be provided in “good faith,” the groups noted. But they argued the regulatory framework surrounding tolerances has evolved into an overly technical compliance regime that can penalize lenders for immaterial differences rather than focusing on whether consumers received meaningful and accurate information about the costs of their mortgage.
Amend the Definition of an “Application” Under TRID. R
Regulation Z currently defines a mortgage application based on a lender’s receipt of six pieces of information, triggering a requirement to provide a Loan Estimate within three business days.
The trade groups recommended expanding that definition to include the six existing data points along with additional information a creditor may reasonably need to make a credit decision.
The CFPB rejected a similar proposal when it adopted the rule in 2013, reasoning that allowing lenders to require additional information could delay delivery of Loan Estimates.
The groups said experience since then has demonstrated that eliminating such a provision can instead result in incomplete or unreliable Loan Estimates.
“Market experience, however, has made clear that removal of the catch-all provision results in the issuance of incomplete or unreliable Loan Estimates, resulting in consumer confusion and limited utility, as creditors lack the information to provide a reliable disclosure,” the organizations said.
Clarify and Expand the Definition of a “Bona Fide Personal Financial Emergency.”
TRID permits consumers to waive certain waiting periods when they face what the regulations define as a bona fide personal financial emergency.
The groups said the definition is too narrow and should be clarified to cover circumstances in which delays could cause significant financial harm to borrowers.
They recommended that the CFPB specifically recognize situations involving the imminent loss of earnest money, expiring interest-rate locks, firm relocation or occupancy deadlines, contractual penalties and cascading settlement delays.
A clearer and broader standard, the groups said, would preserve consumer choice while allowing mortgage lenders to respond when delays threaten meaningful financial harm.
The joint recommendations were submitted in response to CFPB Docket No. CFPB-2026-0018.
The organizations said they share the CFPB’s goal of promoting a transparent, efficient and competitive mortgage market and argued their proposed changes could reduce unnecessary compliance friction while making mortgage disclosures more useful to consumers.
Opportunities to Simplify & Lower Costs
“Our organization’s individual responses will identify opportunities to simplify and lower operational costs and we encourage the Bureau to use the results of this RFI process to consider appropriate revisions to the rules,” the groups said.
The organizations also said they are prepared to work with the CFPB as it considers changes aimed at improving the availability, affordability and efficiency of the nation’s mortgage finance system.
