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CFPB Proposes New RESPA/TILA Rule and Disclosure

The Consumer Financial Protection Bureau (CFPB) on July 9, 2012 issued its much anticipated proposed rule and forms to combine certain disclosures required under the Real Estate Settlement Procedures Act (RESPA) with disclosures required under the Truth in Lending Act (TILA), as required by the Dodd-Frank Act.  The proposal also addresses new disclosure requirements required by the Dodd-Frank Act, and provides "extensive guidance" on how to complete both the new "Loan Estimate," designed to replace the existing Good Faith Estimate and the "early" TIL disclosures, as well as the new "Closing Disclosure," which is proposed to replace the existing "final" TIL disclosures and the HUD-1 Settlement Statement.  Credit Union National Association (CUNA) is preparing two separate comment calls relating to the proposed rule, the first of which is located here.  CUNA's second comment call will have additional details on the requirements contained within the proposed rule, which CUNA will have completed in an upcoming regulatory advocacy report.

Most of the proposal has a comment deadline of November 6, 2012, but there are two significant provisions discussed in CUNA's  initial comment call which have a comment deadline of September 7, 2012.  Leagues and credit unions are urged to provide comments on these two sections by August 10, if at all possible, so that CUNA can circulate their initial comment letter.  CUNA will be working with its Consumer Protection Subcommittee, as well as the CUNA Housing Finance Reform Task Force, the CUNA Lending Council and the AACUL Regulatory Advocacy Advisory Committee as they formulate their comments on the proposed rule in the coming weeks.

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