The CFPB is a favorite whipping boy for banks of all stripes. As a child of Dodd-Frank, the CFPB is not exactly on the Christmas card list of most bankers.
But, the new mortgage disclosure forms look like genuine progress to me. And, the bonus is the clear compliance direction the CFPB has provided for banks. Simple. Direct. Understandable.
The new disclosures, are officially entitled a very respectable mouthful: “Integrated Mortgage Disclosures under the Real Estate Settlement Procedures Act (Regulation X) and the Truth In Lending Act (Regulation Z)” See link at end of story.
But, don’t be put off by the title. The good thing is now mortgage providers have a level playing field figuring out what goes in the Amount Financed boxes. The instructions are written in sub-college English and the directions and commentary are comprehensive. For the first time in a long time banks and their examiners will be on the same page with disclosure requirements. Frankly, once these new disclosures are implemented (effective date for compliance is a reasonable August 15, 2015 ) examinations will be less harrowing. Life will be good. OK, better.
Another reason for cheer: the new compliance forms replace the unwieldy (not to mention confusing and awkward) disclosures required by RESPA and Truth in Lending. Even forms vendors should love the simplicity.
Like a most people in the industry, I think the whole Dodd-Frank thing is an enormous pain. The hoops banks have been required to jump through (on TLA “modernization” as just one example,) are complete overkill. But not withstanding all that, these new integrated disclosures are a good thing. Hard to believe they came from a regulator. (Here’s a thought: maybe a closer reading of Dodd-Frank would disclose the need for a TPBP (Tax Payer Protection Bureau) mandated to rescue us from the malaprops in government.)
Want to talk about how the new disclosures will affect your compliance and disclosure procedures? Send me an email with INTEGRATED in the subject line — or call me 800-544-8269.