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RESPA/TILA Know Before You Owe Project - Update

On July 6, the Consumer Financial Protection Bureau (CFPB) posted another blog entry giving more details on the specifics behind the entire Know Before You Owe mortgage disclosure project.  The CFPB states that “Soon, [it] will submit a Notice of Proposed Rulemaking to the Federal Register to begin the public notice–and-comment process.”  Notably, the CFPB also indicates that when it does so, it will also release a “lot of interesting information [on its Web site]:  a side-by-side comparison of the existing forms and the new ones, reports on what [they] learned from testing the forms and from [their] discussions with small businesses, a timeline of the project leading up to this point, and a new way of presenting the rules and commentary that tell industry how to fill out the forms.” 

The CFPB indicates that these blog entries are the first in a series, and Credit Union National Association (CUNA) expects that the proposed RESPA/TILA rule will be released very soon, perhaps as early as next week.  The proposed rule and proposed combined forms are to be issued not later than July 21, 2012, according to the Dodd-Frank Act.  In addition to working with CUNA’s Consumer Protection Subcommittee and Housing Finance Reform Task Force, CUNA continues to work closely with the CFPB in all aspects related to this and other mortgage rulemakings required by the Dodd-Frank Act, in an ongoing effort to minimize the impact of the various rules to be issued by the CFPB this summer in the area of mortgage lending.

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