Share
February 6, 2012
On Friday, January 27, 2012, NAR submitted an industry letter to Consumer Financial Protection Bureau (CFPB) Director Richard Cordray asking that the CFPB be more forthcoming in the underlying regulations governing the harmonization of disclosures and form under RESPA and TILA. The CFPB has been very open in its process of developing proposed forms and has been seeking industry and consumer input for nine months. However, it has become clear that further informed comments on the effort cannot be made without knowledge of the underlying regulations that will govern the forms. In fact at this point it is felt the underlying regulations are more important than the forms themselves.
The industry trade groups also suggested that CFPB step up small business involvement in the process and establish small business panels required under existing to review the impacts to small business. Finally, the letter suggests CFPB test the forms with existing loan files in a variety of markets to ensure that the forms and regulations actually mesh with local laws, practices, and customs. Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, the CPFB is required to propose a regulation by July 21, 2012.