“ABA has long supported simplifying RESPA and TILA mortgage disclosures; however, we are concerned that the CFPB’s 1,100 page proposal fails to both simplify the disclosure and consider other ongoing reforms.

“Regulators and the industry must take time to consider the full impact of proposals that rewrite the entire mortgage origination process. This is a massive undertaking, and it is important that reform is workable while actually simplifying the disclosures.

“Moving forward, disclosure reforms must be coordinated with servicing, compensation, and consumer protection reforms to ensure we are creating a system that is clear and efficient for consumers and lenders.”