CUNA Senior Assistant General Counsel Michael Edwards and NAFCU Assistant Associate Director of Regulatory Affairs Dillon Shea both wrote that that they support the aspects of the proposal allowing consumers to orally verify their employment status and letting the Pentagon's employee database verify the employment status of military personnel. Though Shea said defense credit unions should be allowed to use other data bases if they have reliable ones.

Edwards praised the part of the proposal to let balloon payment mortgages be considered qualified mortgages if made by lenders in rural or underserved areas that have assets of less than $2 billion.

But both Edwards and Shea argued that the definitions of underserved and rural counties are too narrow. For example, the rule said a county is underserved if it only has one creditor that makes five or more mortgages. 

Shea wrote that the proposal's provisions about the compensation of loan originators is “unnecessarily broad.” And he criticized the “micromanagement” of the disclosure process and said bonus compensation shouldn't be limited because it is being paid by the lender, not by the borrower.