“While we understand that Title XIV of the (Dodd-Frank Act) provides a set effective date for the agency's 'qualified mortgages,' the CFPB can assert its greater discretionary rulemaking, examination and supervisory authorities to determine that 12 months is an inadequate period for financial institutions to effectively implement the regulations.” she wrote.

Or, NAFCU suggested, the bureau could use its “broad authority” to provide an extended effective date for all credit unions, on the grounds that they are “small entities.”

NAFCU believes Congress granted the CFPB this authority when dealing with smaller organizations because it understood that any new rules would have a deeper impact on them than on larger competitors. “As you consider our request, we also ask that you contemplate the interplay between the various mortgage rules that the agency will be finalizing next month and the mortgage disclosure rules integrating the Truth-in-Lending Act and Real Estate Settlement Procedures Act (RESPA) disclosure forms,” Hunt added.

“The agency has indicated that it will likely issue a final rule on the combined mortgage disclosures in the summer of 2013. Thus, it would be helpful to credit unions, and ultimately their 94 million members, if the CFPB delays the determination of the effective dates of the mortgage rules due in January until it finalizes the combined mortgage disclosure rules,” Hunt's letter said.