Defense Credit Union Council Responds to CFPB’s RFI, Promoting Access to Mortgage Credit

By DCUC Staff — August 12, 2026

WASHINGTON, D.C. -- The Defense Credit Union Council (DCUC) recently responded to the Consumer Financial Protection Bureau’s (CFPB) Request for Information Regarding Promoting Access to Mortgage Credit [Docket No. CFPB-2026-0018].

Representing more than 200 defense-affiliated credit unions serving over 40 million members, DCUC noted the important role of credit unions in providing relationship-based mortgage lending to consumers who may not fit standardized lending models. “Consumer protections should be preserved, but the CFPB should eliminate requirements that do not materially improve consumer understanding and that disproportionately burden credit unions,” says Jason Stverak, DCUC Chief Advocacy Officer. DCUC's recommendations focus on preserving the core consumer protections of the Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA), while providing greater flexibility in how mortgage regulations are implemented. Specific recommendations include: Modernizing TRID timing and disclosure requirements to reduce unnecessary delays when changes have little or no impact on a consumer's decision to proceed with a transaction. Eliminating the three-business-day rescission period for rate-and-term refinances, where borrowers have already received and had an opportunity to review the Closing Disclosure. Providing greater flexibility for smaller credit unions, including tailored requirements and safe harbors that recognize the limited resources and lower mortgage volumes of smaller institutions. Expanding electronic mortgage processes by providing clearer guidance supporting electronic disclosures, signatures, remote processes, and digital document delivery. Reviewing tolerance thresholds and other requirements where costs cannot reasonably be determined or controlled by the creditor at the time of application. “These recommendations are about making the mortgage process work better for consumers without compromising the protections that matter,” says Anthony Hernandez, DCUC President/CEO, Ret. U.S. Air Force Colonel. “Servicemembers and military families often face tight timelines when relocating or making a permanent change of station, and their credit union should be able to provide timely access to mortgage credit without unnecessary regulatory delays.” DCUC highlighted the unique challenges faced by smaller credit unions, which often operate with fewer employees, more limited compliance resources, and smaller mortgage portfolios. Fixed compliance costs can make certain mortgage products difficult to offer, limiting consumer choice in communities where smaller financial institutions are an important source of credit. “Credit unions are particularly well-positioned to serve borrowers whose circumstances may not fit conventional lending models,” Stverak adds. “Modernizing outdated processes can help preserve that access while allowing credit unions to focus their resources on serving members.” DCUC encouraged the CFPB to establish clear principles and meaningful consumer protections while giving financial institutions greater flexibility to determine how best to communicate information and deliver mortgage services in an increasingly digital environment. See DCUC’s official comments here.

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Originally reported by DCUC.