Mortgage Bankers Urge Stronger CFPB Approach to Mortgage Disclosure Revamp

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




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  • This is a terrible mistake by the MBA.  Their letter should have not mentioned Ms. Warren, let alone be addressed to her.  It is she who has assumed the mantle of Director.  It is not up to our industry to “don” or “inaugurate” her.  This is an insult to the first Director if it is not Ms. Warren.  The position Ms. Warren was appointed to did not include the Directorship during the transition to the July 21, 2011 start date.
    The Obama administration fought for this legislation and particularly the CFPB but as usual this President has chosen not to lead.  He has yet to do one thing about a Director.
    July 21 is two weeks away.  With the debt ceiling issues where will the Senate find the time to appoint the Director by the required date?  If there is no Director on July 21, let the CFPB die for want of presidential leadership.  The President has not been presented the Senate with a single name to be considered for its Director.
    It is not House Republicans who have stopped the President; they cannot stop him from naming nominees for Senate confirmation.  The President has chosen this to excuse his own lack of leadership by seeming to blame them.  The President needs to act and act now.  If there is no Director by July 21, there is no one to blame but the President.

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