Last month, as part of its “Know Before You Owe project,” the CFPB began taking comments on two prototypes (named Hornbeam and Ironwood) of a settlement disclosure that combines the final TILA disclosure and the RESPA HUD-1 Settlement Statement. The CFPB received over 3,000 comments on the prototypes. This week, based on those comments, the CFPB posted two new prototypes (named Mimosa and Sassafras) on its website which it will be testing in Birmingham, Alabama and on which it is requesting public input.… Continue Reading

We reported that they were coming and now they’re here. This week, on its website, the CFPB began taking comments on two draft designs of a disclosure that combines the final TILA disclosure and the RESPA HUD-1 Settlement Statement. A “consumer tool” asks consumers which form they would prefer to be given at closing to describe final loan terms and closing costs while an “industry tool” asks industry members “which format” they would prefer for their customer “to use at closing” to describe those items.… Continue Reading

In an earlier post about the CFPB’s “Know Before You Owe” project, I commented that it was unclear how the CFPB intended to approach required RESPA/TILA disclosures other than the early TILA disclosure and the RESPA good faith estimate. The project was launched in May to design a simplified mortgage loan disclosure combining the disclosures required by TILA and RESPA.… Continue Reading