Combined Early and Final Disclosures. The Consumer Financial Protection Bureau (CFPB) has issued proposed rules to combine disclosures required under the Truth in Lending and Real Estate Settlement Procedures Acts. The proposed rules combine the Early Truth-in-Lending Disclosure and Good Faith Estimate documents into a new document called the Loan Estimate. On the closing end, the Final Truth-in-Lending Disclosure will be combined with the HUD-1 into a new document called the Closing Disclosure.
These changes are substantial and as such, the CFPB is specifically seeking input as to the amount of time required for your institution to implement procedures to ensure a seamless transition to the proposed new rules. You can comment directly on the CFPB’s website. According to the CFPB, “You have until November 6, 2012 to review and provide comments on most of the proposal. However, comments are due for two parts on September 7, 2012: the changes to the calculation of the finance charge and Annual Percentage Rate and the delay of the effective date for certain disclosures required by the Dodd-Frank Act.”
High Cost Mortgage Updates. In addition to the combined disclosures, the CFPB published a proposed rule expanding the scope of loans subject to the Home Ownership and Equity Protection Act of 1994. This rule imposes additional restrictions on high cost mortgages such as a counseling requirement and expanding the triggers for what is considered High Cost. Comments are generally due by September 7, 2012.
Find summaries and additional information for both rules here: http://www.consumerfinance.gov/knowbeforeyouowe/