CFPB wants comments on plans for testing mortgage servicing disclosures and collecting compliance cost information


Two recent notices published by the CFPB in the Federal Register shed some light on the CFPB’s plans for testing the mortgage servicing disclosures it’s developing and for collecting information about the potential compliance costs of its proposals.

A notice published on May 11 seeks comments on the CFPB’s plans to qualitatively test mortgage servicing related model forms and disclosures. The research is to primarily be conducted by “an external contractor employing cognitive psychological testing methods,” an approach that, according to the CFPB, has been shown to be “feasible and valuable” in developing disclosures. Comments are due by July 10, 2012.

Another notice published on May 15 seeks comments on the CFPB’s request for “generic clearance” from the Office of Management and Budget of the CFPB’s efforts to collect “qualitative information on the potential costs of complying with potential new regulations and other effects the rules may have for providers and consumers.” The CFPB states that, through its collection of such information, it “seeks to ensure that it has considered the compliance burdens and costs before completing a rulemaking action.”

The CFPB notes that it’s “particularly interested” in collecting information on the impact of its proposals on the unit costs of delivering specific consumer financial services and products because this will help it determine whether a proposal has “unncessary costs for providers or consumers.” The CFPB intends to obtain cost information through structured interviews, focus groups, conference calls, written questionnaires, and online surveys. The CFPB also states that because it recognizes that burdens are not the same for all institutions or all products and services offered, it will attempt to sample providers “that are representative of affected markets.” Comments are due by June 19, 2012.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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