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On Monday, July 9, 2012, The Consumer Financial Protection Bureau (CFPB) issued the long awaited RESPA/TILA harmonization proposal. The proposal, at 1,100 pages is far more ambitious than simplifying and combining the Good Faith Estimate (GFE) and Truth in Lending (TIL) disclosures given to consumers upon application for a mortgage as NAR advocated.
The proposal contains many significant changes to the settlement process including combining the HUD-1 Settlement Statement and the final TIL into a single document to be provided by an undetermined party three days before closing. While the CFPB took NAR's advice and provided some exceptions to the mandatory three day waiting period, it remains to be seen if these are adequate to cover the vast majority of last second eventualities that would cause neither buyer or seller to want to wait three days close but may have to under this proposal.
The proposal is extensive and also contains changes to the APR, changes to what and how items are disclosed, when an initial disclosure must be issued, and myriad other issues. NAR will offer extensive comments.
Comments on the vast majority of the proposal are due November 7, 2012.