New Mortgage Disclosure Paperwork – Confused yet?

4-4-2014: The CFPB just released 89 pages of guidelines for TILA-RESPA Integrated Disclosure Rule – (i.e., disclosure forms to be used for real estate closings) to be implemented on and after August 1, 2015.

Note: The TILA-RESPA rule consolidates four existing disclosures required under TILA and RESPA for closed-end credit transactions secured by real property into two forms: a Loan Estimate that must be delivered or placed in the mail no later than the third business day after receiving the consumer’s application, and a Closing Disclosure that must be provided to the consumer at least three business days prior to consummation.

11-20-2013: The new mortgage disclosure form is due out today and should be announced by Richard Cordray and the CFPB – this form is designed to blend and “simplify” the TILA & RESPA required disclosures to make it easier for the consumer to compare home loans when they shop for a mortgage. We will see…

Ok, the buzzer went off – it’s too late to comment. or is it?

Furthermore, you can’t cry to Congress over CFPB behavior since they are funded 100% by the Federal Reserve.

8-24-2012: Well, here’s your opportunity to comment on the proposed mortgage disclosure forms: http://www.consumerfinance.gov/knowbeforeyouowe/

We are in a period of transition in real estate – from common sense to “dumbing down confusion”.

As a home buyer purchasing a home or a homeowner refinancing your home, you will soon be presented with two newish forms – GFE and Settlement Disclosure.

The GFE form essentially will look like this:  GFE Format

The two draft Settlement Disclosure forms (Butternut and Hemlock)  are under review but are to be published in August 2012.

I find it sad and humorous that the Consumer Financial Protection Bureau (CFPB), charged with protecting consumers, places the closing attorney charges on both forms under “Services that the Buyer did not not shop for” and yet the title insurance issued at closing depends on who the closing attorney uses or prefers.  Where’s the consumer protection placed here?

References to products and services are not a specific endorsement, but the user must perform their due diligence and investigate whether the product or service is right for them. I welcome any or all comments that would help others.

This entry was posted in Uncategorized. Bookmark the permalink.

Leave a Reply