NAR Comments on RESPA/TILA Proposal to Change APR
On Friday, Aug. 31, 2012, NAR submitted comments to the Consumer Financial Protection Bureau (CFPB) on a small part of the 1,100 page RESPA/TILA harmonization regulatory proposal seeking to change the annual percentage rate or APR calculation. While most of the comments for the regulatory proposal are due in November, this section is due Sept. 7.
NAR advised the CFPB to abandon efforts to create an "all in" APR and focus their efforts on improving the new combined RESPA/TILA loan estimate that replaces the good faith estimate and the truth in lending disclosure. As many in the industry know, consumers do not understand and do not use the APR. Changing its calculation will not alter that and is not useful.
NAR expects to comment more extensively on the broader RESPA/TILA rule in the fall.