During the past few months we have received many questions about the new mortgage rules that will become effective in January 2014. With these questions, we have also received a few questions about the new TILA/RESPA disclosures requirements, which are anticipated to be released later this year by the CFPB.
A number of these questions have revolved around the proposal that would require that consumers receive the final disclosure within three days before closings, and another three-day waiting period would be added if loan terms or costs change. Credit unions have stated that this might be an issue as closing costs and loan figures sometimes change within the 3 days before closing.
Richard Cordray, the head of the Consumer Financial Protection Bureau (CFPB), released a letter to Congress that stated that the CFPB is listening to all comments in regards these new rules.
In the letter, Cordray stated that “The Bureau understands your concern about delayed closings,” and that things do sometimes change between the time of a three-day disclosure and the closing, and that not all changes justify delaying the closing date. Cordray also added, “The Bureau is reviewing these comments carefully to determine the most appropriate way to provide meaningful consumer disclosures while, at the same time, avoid unnecessary delays in closings.”
Could this be a silver lining for these yet to be released final rules? Stay tuned to when those final rules are released to ensure your credit union is ready for any requirements the CFPB may make.