On Thursday, Dec. 13, 2012, The Consumer Financial Protection Bureau (CFPB) announced its proposed policy to allow companies to test new consumer disclosures on a case-by-case basis. As part of its Project Catalyst initiative, the Bureau’s goal is to encourage banks, credit unions, and other financial services companies to propose and conduct trial disclosure programs by offering them waivers in exchange for the valuable feedback they provide. NAR in its meetings and through its comments strongly advocated further testing and refinement of proposed RESPA/TILA forms with consumers. CFPB is apparently moving in that direction ahead of finalizing the RESPA/TILA rule. If executed properly, there is the potential to avoid significant expense and confusion once a final rule is issued.
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