As we reported last week, the CFPB announced that it was wrapping up testing of its integrated mortgage disclosure prototypes and gearing up for the rulemaking process. Because the CFPB’s rule will have a significant impact on a substantial number of small business entities, the CFPB must convene a small business panel before issuing its proposal as required by the Small Business Regulatory Enforcement Fairness Act (SBREFA). Materials released by the CFPB to prepare for the SBREFA process not only address the prototype disclosures but provide a window into the CFPB’s thinking on the rules that will govern those disclosures. We have prepared a legal alert that discusses in detail the changes to the existing rules that the CFPB is considering.
