TILA-RESPA Integration – Mortgage Disclosure Reform

Issue

The Consumer Financial Protection Bureau in November 2013 published revised final rules and forms that combine disclosures that consumers receive in connection with applying for and closing on a mortgage loan under the Truth in Lending Act and the Real Estate Settlement Procedures Act. The new integrated disclosures apply to most closed-end consumer credit transactions secured by real property.

ABA's Position

ABA has consistently supported efforts to improve mortgage costs disclosures and is pleased that the CFPB engaged in an open regulatory process that allowed banks to recommend many of the improvements reflected in the final rule. ABA believes, however, that opportunities were missed in truly reforming these disclosures. For example, there are still overly complex and ambiguous regulatory calculations that pose cost and liability for banks, and the new forms remain lengthy and intimidating to average consumers. Given the scope and complexity of these new reform rules, the implementation of this regulation will impose extremely high costs on large and small lenders alike. ABA will work to ensure that members have access to resources needed to adequately comply.

 

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 Letters to Congress/Regulators

 
 

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 Rules and Issuances

 

Questions? ​Contact Rod Alba for more information.