CFPB Releases Drafts of Combined Closing Disclosure
Blog posted by John Zasada
The Consumer Financial Protection Bureau (CFPB) has released two alternative drafts of a combined Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) disclosure given to members at loan closing.
These two draft disclosures are related to the same loan product, and CFPB is asking for input from the public on which version they prefer. Since the TILA and RESPA disclosures at loan closing are being combined into a single form, the new form will have multiple pages. The first draft disclosure is five pages, and the other draft is six pages.
Previously, the CFPB had been testing a combined TILA and RESPA form to be used when applying for a loan. These new drafts for closing represent a shift in the CFPB’s focus from application disclosures to closing disclosures. There will be more closing disclosure drafts released as CFPB receives feedback and subsequently modifies the new combined form.
The two draft disclosures are available online.
What do you think of the new combined form, compared to the current structure of separate TILA and RESPA forms? Contact me with your opinion.