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. In its announcement, the CFPB states that it will be testing the drafts in cities throughout the country and expects to conduct four rounds of testing and revisions through February 2012. The CFPB’s plan is for this process to culminate in a proposed rule to be issued by the CFPB in July 2012 that will request comments on draft forms. We hope the industry will weigh in early and often so its input will have the best chance of being reflected in the draft forms the CFPB ultimately proposes.
