Compliance Blog

May 19, 2011

RESPA/TILA Combined; Liar Liar

Posted by Sarah Loats

Know Before You Owe. Yesterday, the CFPB released two prototype forms it developed to consolidate the disclosures required under RESPA and TILA. The agency is calling it the Know Before You Owe project. The Dodd-Frank Act directed the CFPB to take on this task, and these two forms are the agency's initial attempts at streamlining the disclosures. NAFCU was able to attend a meeting with the CFPB and other industry reps on Tuesday to view the forms before they were released yesterday. Evaluation and revision is expected to go through this fall.  Below is a snippet from the press release.

“Buying a home is one of the biggest financial decisions most Americans will ever make. The Know Before You Owe project is about giving consumers upfront, easy-to-understand information that helps them compare different mortgage offers and find the one that’s best for them,” said Elizabeth Warren, Assistant to the President and Special Advisor to the Secretary of the Treasury on the CFPB.  “The current forms can be complicated and difficult for consumers to use.  They are also redundant and can be costly for lenders to fill out.  With a clear, simple form, consumers will be in a better position to answer two basic questions: Can I afford this mortgage and can I get a better deal somewhere else?”

Of course her emphasis is on consumers, but Professor Warren does throw a bone to credit unions and other lenders. Count me as part of the camp that hopes they can improve the process. With that in mind, if you follow this link, you can provide your own feedback (there is a consumer tool and an industry tool). There are two forms right now - the content is identical but the information is presented differently. Credit unions are encouraged to review the forms and provide feedback.

NAFCU members: Please consider providing your feedback to our colleague Dillon Shea. NAFCU will be in contact with the CFPB about these forms and the more feedback we get, the better information we can pass on to the CFPB.

 

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Liar Liar. From the responses we received from yesterday's blog post, it seems many of you aren't fans of my Buckeyes. Well, this one's for you.

P.S. What is part of Jim Tressel's punishment? Compliance School!