"This is a particularly daunting task for smaller credit unions, given their small staffing resources."
Cheney said his group is hoping that there will be grace period before credit unions that are trying to make sure they are ready to go will be cited for a violation if they are running behind schedule.
The ability of third-party vendors to redesign computer systems to meet the new requirements is a major concern to credit unions, the survey showed.
Overall, 48 percent of vendors indicate they will complete programming changes to comply between November and December, and an additional 10 percent say they won’t be able to develop programming until after January.
A majority, 86 percent, of responding credit unions are using third party vendors to help them, while 69 percent of that group are using multiple vendors. The CFPB has indicated it has talked with vendors.
The survey included comments from respondents: "I do not have a problem with the requirements however I would have preferred the rule dates to be staggered. It is difficult to comply with so many rules at one time. If they were staggered it would give me the time needed to ensure smooth compliance of these rules."
Another said: "We will suspend all mortgage products until we can get forms and networks in place to support the changes. I anticipate this will take until the end of the first quarter before we are ready."