On July 16, 2012, the Consumer Financial Protection Bureau (“CFPB”) posted its Semiannual Regulatory Agenda (“Semiannual Agenda”) as part of its participation in the Unified Agenda process. The CFPB acted in advance of the Office of Management and Budget’s publication of the Spring 2012 Unified Agenda for the entire federal government in order to give the public more time to consider the Bureau’s work. The CFPB’s Semiannual Agenda indicates that it will undertake a number of mortgage-related rulemakings consistent with the CFPB’s authority relating to consumer financial products and services. In this Alert, we describe two pending rulemakings that will affect the obligations of mortgage lenders, brokers, creditors, and appraisers.
Know Before You Owe - Mortgage Disclosure Integration:
The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) requires the CFPB to issue proposed rules and model forms integrating certain disclosures that consumers receive in connection with applying for, and closing on, a mortgage loan under the Truth in Lending Act (“TILA”) and the Real Estate Settlement Procedures Act (“RESPA”). The model forms “will be designed to enhance consumer understanding and provide guidance to lenders and brokers on compliance with amended disclosure requirements.” Semiannual Agenda at p. 13. According to the proposed rule, the CFPB “engaged in extensive consumer and industry research and public outreach for more than a year” in order to develop the integrated forms with a detailed explanation of how the forms should be filled out and used. Id. at 3.
Please see full Alert below for further information.
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