An updated list of rural and underserved counties where lenders are exempt from certain Truth in Lending Act (TILA) mortgage rule requirements has been published by the Consumer Financial Protection Bureau (CFPB) and announced to credit unions in a recent message from the National Credit Union Administration (NCUA).
“Credit unions that make at least one first-lien mortgage loan secured by a property located in a rural or underserved area during 2019 qualify as a creditor operating in a rural or underserved area during 2020, and for loan applications received before April 1, 2021,” NCUA said in a Consumer Financial Protection Update (No. 19-07) Thursday.
The alert notes the CFPB’s publication of the 2019 counties lists – one for both rural and underserved counties, and another showing just rural counties – as well as a tool creditors can use to check the status of properties for loans extended this year. “Your credit union may rely on the more comprehensive website tool to provide a safe harbor determination whether a property is located in a rural or underserved area,” the NCUA update notes
The CFPB itself notes that the tool is more comprehensive than the lists because the lists reflect rural status only at the county level; the tool includes both locations that are rural because they lie in rural (non-urban) census blocks and locations that are rural because they lie in rural counties.