Consumer Financial Protection Bureau
ALTA Task Force Meets With CFPB; Shares Concerns of Draft Final Disclosure
|December 6, 2011
ALTA's RESPA Task Force met today (Dec. 6) with staff from the Consumer Financial Protection Bureau (CFPB) to discuss concerns with the Bureau's draft settlement disclosure forms and the RESPA reform process.
The CFPB is combining the Truth in Lending disclosure and HUD-1 Settlement Statement to create a new HUD-1. In its first effort to combine the forms, the CFPB created two drafts: a six-page form called Ironwood Bank and a five-page disclosure called Hornbeam Bank. The Bureau expects to conduct four more rounds of testing and revisions through February 2012.
To improve the draft settlement disclosure form, the Task Force suggests the Bureau:
- Separate the form into two parts;
- Make the form a final disclosure;
- Itemize for transparency;
- Reform the use of tolerances;
- Discontinue the use of provider lists;
- Connect the initial disclosure to the final disclosure;
- Improve the Paid Outside of Closing column; and
- Work with software providers.
The Task Force sent a letter
to the Bureau explaining these issues in detail.
“As it reviews each draft disclosure issued by the CFPB for feedback, ALTA’s Task Force focuses on two questions: how should the closing disclosure benefit a consumer; and, how should real estate settlement providers utilize the form?” the Task Force said in its letter to CFPB.
The Task Force has also created chart
a describing all of its concerns with the form, as well as suggested solutions to make the form easier to use for consumers and the industry.
As with all of the Task Force's meetings with HUD and the Bureau over the past three years, the goal is to continue to be a resource to policymakers on RESPA issues. If you have questions for the CFPB please reach out to Steve Gottheim
, ALTA’s legislative and regulatory counsel.