CFPB Releases Third Round of New Closing Disclosure Prototypes
|January 26, 2012|
The Consumer Financial Protection Bureau released its third round of new closing disclosure prototypes and is seeking feedback on how these forms work with the Bureau’s current application disclosure prototype.
The CFPB is combining the Truth in Lending disclosure and HUD-1 Settlement Statement to create a new HUD-1. It previously held five rounds of testing prototypes of a new application disclosure and is now testing drafts of a new closing disclosure. In this round, the CFPB is asking for feedback on how the new closing disclosure prototypes work with the current draft of the application disclosure prototype.
The five-page closing disclosure forms in this round are called Butternut and Hemlock. The application prototype can be viewed here.
The CFPB is testing this version of the closing disclosure form in Philadelphia. To provide feedback, the CFPB asks for comments to be made on its blog or sent via email. If you would like to contact ALTA with concerns, send an email to Steve Gottheim, ALTA’s legislative and regulatory counsel. The side-by-side comparison tool is not being used this round.
In reviewing testing from the second round, which compared two settlement disclosures, Mimosa and Sassafras, the majority of responses found the Sassafras form more consumer friendly because closing costs were formatted similar to the application disclosure prototype. However, some told the CFPB it shouldn’t eliminate line numbers because they are helpful to industry software systems that produce HUD-1 settlement statements. ALTA’s RESPA Task Force has encouraged the Bureau to maintain the current section and line numbering on the HUD-1 to the greatest extent possible to allow for faster and less costly software development and implementation.
In reviewing the forms, the CFPB would like you to think about these questions: