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Consumer Financial Protection Bureau

ALTA Participates in CFPB Roundtable on RESPA/TILA Forms

March 26, 2012

On Tuesday, ALTA participated in a roundtable discussion between CFPB rule-writing staff and real estate and mortgage finance industry trade associations on the RESPA/TILA forms. This meeting was designed as a kind of mini-Small Business Regulatory Enforcement Fairness Act (SBREFA) panel, so that the Bureau could receive feedback from industries and trade associations that did not have participants serving on the SBREFA panel.

During the hour-long meeting, ALTA lobbyists pushed the Bureau staff to recognize that many of their policy decisions listed in CFPB's regulatory outline (such as the three-day rule and expanding tolerances for lender affiliates and companies on a lender's provider list) will have real-world consequences that could be detrimental to consumers and small businesses. ALTA staff reminded them that these changes could really harm small title companies and urged the CFPB to carefully consider alternatives that would not hurt small businesses and title agents.

While there was a healthy back and forth between the CFPB and industry, we are concerned that the CFPB is resistant to changing its proposed regulatory outline ahead of its July 21st deadline. This perceived resistance appears to be due to the CFPB's unfamiliarity with how its proposed rules would impact business. During the meeting, CFPB staff frequently asked the question, "What will you not be able to do under the new forms that you can do today?" While ALTA lobbyists provided some of the answers to this question during the meeting and in our SBREFA letter, it will be a lot more effective if the answers come directly from you. Let me explain.

If ALTA is going to be successful in persuading the CFPB to make less harmful changes to the RESPA forms and regulations we need your help. I urge you to tell your story of how the CFBP's proposals will impact your business; how much you believe these new forms will cost you to implement and in lost revenue; and why you believe these new rules will harm consumers from your vantage point. This is not a battle that we can win without your help. Please let the CFPB know your thoughts on their rule by April 15th at

For more information on this topic, please contact ALTA Vice President of Government and Regulatory Affairs Justin Ailes at

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