Topics In This Issue:
• Federal Issues
• State Issues
• Firm News
• Consumer Finance
Excerpt from Federal Issues:
CFPB Releases Prototypes of Combined Final TIL and HUD-1 for Public Comment. On November 8, the Consumer Financial Protection Bureau (CFPB) released for public comment two alternative versions of a new mortgage disclosure form that would effectively combine the current disclosure requirements of the final federal Truth in Lending (TIL) and HUD-1 Settlement Statement forms. The release of these prototype forms marks the second phase of the CFPB's Know Before You Owe program designed to revamp consumer disclosures relating to mortgages with the first phase being CFPB's release of a combined initial TIL and Good Faith Estimate (GFE) form. A primary feature of both versions of the proposed disclosure is a prominent text box that highlights whether a mortgage loan payment or interest rate can change during the life of the loan. The CFPB stated that it considered public and industry feedback on the combined initial TIL and GFE during development of the combined final TIL/HUD-1 prototypes. In addition to soliciting public comments, the CFPB will hold substantive discussions with members of the public and mortgage industry representatives as part of its testing process. The CFPB expects to release the draft forms for official notice and comment rulemaking in July 2012, as required under the Dodd-Frank Wall Street Reform and Consumer Protection Act.
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