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. Since then, the CFPB has requested feedback on four rounds of drafts of a combined early TIL and GFE.
Last week, the CFPB announced on its web site that it was testing another revised design of this combined disclosure “with consumers and industry” in Albuquerque, New Mexico. While posting the latest design, the CFPB told its web site visitors that it wasn’t asking for feedback but instead was “giving [them] a break for this round.” At the same time, the CFPB announced that it would soon be sharing and asking for feedback on a draft closing disclosure that combines the final TILA disclosure and the RESPA HUD-1 Settlement Statement. And even though comments made by Pat McCoy of the CFPB led us to believe the CFPB was close to wrapping up at least the combined early TIL and GFE, the CFPB is now telling its web site visitors that “this isn’t the last you’ll see of the application disclosure. It needs to work together with the closing disclosure, so we’ll be asking for your feedback on both in the future.”