New Mortgage Disclosures and APR Changes Costly to Consumers and Community Banks
ICBA filed two comment letters on Tuesday with the CFPB regarding the Bureau’s proposed rules on RESPA and TILA that will integrate three key mortgage disclosures. The Bureau is tasked with combining the Truth in Lending (TIL) Disclosure under Regulation Z and the Good Faith Estimate (GFE) under Regulation X, into one form now called the Loan Estimate. The CFPB is also renovating the HUD-1 and HUD 1A settlement statement, which will now be called the Closing Disclosure.
While the model forms themselves are a vast improvement over the current GFE, TIL and HUD-1 forms, the policy governing their use has broad impacts on community banks and will be costly to implement
----IICBA News
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