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ABA: The American Bankers Association

TRID Compliance Simplification

Simplifying the Overly-Complex TILA-RESPA Integration Disclosure Rule for Consumer Mortgages

ABA 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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Rod Alba

SVP, Real Estate Finance, Mortgage

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Blair Bernstein

(202) 663-5468

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