CFPB Says One More Round of Mortgage Disclosure before Turning to HUD
|October 11, 2011|
Staff for the Consumer Financial Protection Bureau (CFPB) told ALTA’s RESPA Task Force the Bureau will release on more round of draft mortgage disclosures before turning to the HUD-1 Settlement Statement.
During a conference call with the Task Force, CFPB staff said it plans to release another draft of the combined TILA/RESPA mortgage disclosure form this month, before releasing a draft of a new HUD-1 by the end of the year.
The Task Force held the conference call with the CFPB to get a better understanding of the Bureau’s timeline, and address several other outstanding questions including if the forms are intended as disclosure of the mortgage loan or of the entire transaction and its costs; if the initial disclosure form will be provided to consumers once or multiple times during the loan process; if the new disclosure will interact with the final disclosure; and several other questions.
Once the Bureau begins working on drafts for the HUD-1, the CFPB said it will focus on design first, just like it did with the initial disclosure. CFPB staff would not confirm if tolerances will survive onto the new settlement form.
The Task Force once again urged the Bureau to appropriately disclose owner's title insurance and information that can vary, depending on jurisdiction, and urged CFPB to create a final disclosure showing all disbursements. The Task Force also shared concern about the issuance of multiple GFEs and how it confuses consumers. The Bureau told the Task Force the initial disclosure will be provided to consumers once, but there will be rules for re-disclosure.
According to CFPB staff, they want the mortgage disclosure to help consumers comparison shop the cost of different loan products, but are aware of how things happen in the real world.
As a reminder, ALTA encourages members to post comments to the CFPB “Know Before You Owe” website when the Bureau releases its next round of prototypes.