Credit Union Trade Group Urges CFPB to Ease Mortgage Disclosure Rules

The CFPB sought public input on potential regulatory changes to reduce mortgage compliance burdens and promote credit access, prompting America's Credit Unions, an industry trade group, to urge the agency to ease Truth in Lending Act/Real Estate Settlement Procedures Act Integrated Disclosure ("TRID") requirements.

The agency issued the request for information in response to a March 2026 executive order directing it to seek input on ways to promote mortgage credit access. In an August 7, 2026, joint trade association letter, America's Credit Unions said the CFPB should re-evaluate and revise TRID's tolerance provisions. The association argued that the complexity of the tolerance requirements frequently results in substantial compliance costs that provide little corresponding consumer benefit. Three days later, America's Credit Unions followed with a standalone letter seeking a materiality-based framework with safe harbors for minor or technical errors.

The association also asked in the joint letter that the CFPB broaden the definition of "Application" under TRID to include the existing six required data points plus any additional information a creditor may reasonably need to make a credit decision.

The joint letter further urged the CFPB to clarify and expand the definition of "Bona Fide Personal Financial Emergency." The association asked that the standard explicitly cover real-world financial harms such as imminent loss of earnest money, expiring rate locks, firm relocation or occupancy deadlines, contractual penalties, and cascading settlement delays.