In a letter sent to White House Special Advisor Elizabeth Warren at her Consumer Financial Protection Bureau post, the Mortgage Bankers Association urged the CFPB to meet with industry representatives to discuss the recent versions of mortgage disclosure forms the bureau released for public comment and feedback.
The CFPB has released two rounds of revamped forms in draft state and is has promised subsequent rounds of drafts and comment collection on the forms, which aim to combine the Truth in Lending and the Good Faith Estimate forms, an effort mandated under the Dodd-Frank Act.
The comment period that followed the release of the disclosure drafts is not sufficient, MBA wrote. Instead of an expedited comment period on the subject, the letter urges, MBA and industry representatives should meet with the bureau.
“We urge that the Bureau meet with key stakeholders as soon as possible,” MBA said. “A meeting at this point could provide lenders a better understanding of the direction of the project so they could offer more informed comments and offer stakeholders an opportunity to explain challenges under RESPA and TILA and the practical concerns posed by the current prototypes.”
MBA also noted the broad set of users of the disclosure forms, a point which the National Reverse Mortgage Lenders Association has also brought to the attention of Warren and her CFPB staff. In June, NRMLA executives met with Warren and expressed the difficulty in fitting reverse mortgages into a format that is designed for forward mortgages. At that time, they encouraged the development of a reverse-specific form, according to NRMLA.
“We also believe the Bureau should include practitioners and lenders in the testing the Bureau is conducting to ensure that the Bureau receives feedback from a broader set of users,” the MBA letter said.
View the MBA letter.
Written by Elizabeth Ecker