Letter to the CFPB on Changes to Mortgage Disclosures

To Whom it may concern,

The American Bankers Association (ABA) appreciates the opportunity to comment on the Consumer Financial Protection Bureau's Request for Information (RFI) seeking input on potential changes to regulations governing (1) the TILA-RESPA Integrated Disclosure (TRID) requirements, (2) consumers' rescission rights under the Truth in Lending Act (TILA), and (3) reverse mortgage disclosures and requirements. We applaud the Bureau’s interest in identifying opportunities to reduce unnecessary complexity, improve regulatory clarity, eliminate outdated requirements, and ensure that consumers receive disclosures that are meaningful, understandable, and suited to today's mortgage marketplace. ABA commends the Bureau for undertaking this important review and for recognizing that regulations should be evaluated periodically to determine whether they continue to serve consumers effectively while avoiding unnecessary costs and operational burdens.

ABA has consistently called for focused attention on simplifying and modernizing mortgage regulations. While many of these provisions were adopted with the goal of enhancing consumer understanding and protections, experience has demonstrated that certain requirements create confusion, impose unnecessary compliance costs, increase operational risks, and sometimes hinder, rather than improve, consumers’ ability to navigate the mortgage process. Regulatory requirements should be clear, practical, and focused on delivering information that consumers can readily understand and use.

Overview

ABA believes the Bureau can vastly improve mortgage regulations, not through a broad restructuring of the regulatory framework or sweeping regulatory interventions, but through targeted reforms to a relatively small number of provisions that have proven over time to create outsized compliance burdens, operational inefficiencies, and consumer confusion. Mortgage regulations are deeply interconnected, and incremental adjustments across dozens of requirements often produce limited benefits while creating new layers of complexity. By contrast, carefully calibrated changes to several key provisions, particularly those that drive process delays or create technical liability risk, can generate substantial improvements in efficiency and consumer experience without undermining core consumer protections.

The recommendations advanced below represent the full experience of ABA’s member banks after multiple years of managing challenges associated with TRID. Targeted modernization of these provisions would lower compliance costs while preserving the transparency and consumer protections that Congress intended these laws to provide.

ABA welcomes the opportunity to assist the Bureau in this effort. Our members include institutions of all sizes that originate, service, and invest in mortgage loans across a wide range of markets and customer segments. Drawing on their extensive experience, ABA offers the recommendations below to help the Bureau achieve its goal of streamlining regulatory requirements, reducing unnecessary complexity, and maintaining strong consumer protections. We believe these reforms can improve the efficiency of the mortgage market, enhance consumer experience, and promote broader access to sustainable mortgage credit.

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