Consumer Financial Protection Bureau releases new integrated disclosure form 1
On May 18, 2011, the Consumer Financial Protection Bureau ("CFPB") released two draft RESPA/TILA integrated disclosure forms that consumers would receive within a few days after applying for a loan. The two alternate prototype forms are the first of several proposed forms to be released by the CFPB. The CFPB's stated goal is to provide the consumer with a "single, simpler disclosure form" which combines the two disclosures a consumer currently receives through the Truth in Lending Disclosure Form and the Good Faith Estimate.
This is one of the two alternate prototype forms that are being proposed by the CFPB. The CFPB is currently asking for comments on the two forms to be submitted by May 27, 2011. Comments can be submitted through the CFPB's website at http://www.consumerfinance.gov/. Testing and comment on the two forms is expected to take place over the next several months and will involve one-on-one interviews with consumers, lenders, and brokers. This comment period will precede and inform the CFPB’s formal rulemaking process. The CFPB will also consider underlying regulatory issues and ways to refine closing-stage forms, a process that will likely extend into the fall and early next year. According to the Dodd-Frank Act, the CFPB is required to issue proposed forms and implementing regulations by July 2012 for formal notice and comment.
Please feel free to contact us if you would like more information on what type of comments concerning these proposed forms, and the proposed integration of the TILS with the GFE, to the CFPB would be most beneficial to the settlement services and mortgage banking industries.