CU*Answers is gearing up to modify our regular statement program to include the closed-end mortgage information required per Regulation Z as of January 31, 2014.  The changes planned were outlined in a CU*Answers Announcement dated August 26, 2013.   The credit union comment period ended last week.

Jim Vilker, VP of Professional Services and head of the CU*Answers compliance division, stated “Since the CFPB came out with the interpretation of affiliates we discovered that many of our credit unions fell out of the small servicer exemption”.  We went to work and decided that because of the multitude of notice requirements we needed to develop a periodic statement conforming to the appendix of the rule.  “To date we have yet to miss a regulatory deadline and have not charged our clients anything for the myriad of changes precipitated over the last four years.