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Washington
CUNA meets with CFPB on mortgage disclosure
WASHINGTON (5/26/11)--Just two days before comments are due on the Consumer Financial Protection Bureau’s (CFPB) proposed simplified mortgage disclosure document, the Credit Union National Association (CUNA) met with bureau officials to continue discussions regarding the form. The CFPB, earlier this month, released for comment its "Know Before You Owe" project, which attempts to combine the complicated documents required under the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA) into a single page, two-sided disclosure. Comments using the CFPB’s online interactive “Industry Tool” can be provided through this Friday. At a meeting attended by CUNA earlier this month, CFPB architect Elizabeth Warren that was the first step in a long process of gaining feedback from financial institutions, consumers and other interested parties on the new draft form. After the initial comment period ends this week, the CFPB intends to revise the forms five separate times between May and September, with a final version of the new form scheduled for a July 2012 release. According to CFPB transition team members, each new draft of the form will also be available for online review and comment using the CFPB’s website. The CFPB is concurrently conducting consumer testing of these disclosures in both English and Spanish. At yesterday’s meeting, CUNA Deputy General Counsel Mary Dunn, CUNA Senior Assistant General Counsel Michael Edwards, and representatives from ten credit unions were among those that met with CFPB assistant director for community banks and credit unions Elizabeth Vale and other CFPB representatives. CUNA and credit union representatives will again meet with the CFPB when it releases an updated mortgage disclosure proposal next month. Vale said that the CFPB wants to have frequent dialogue with credit unions as it develops new rules or revamps existing regulations. CFPB representatives during the meeting added that they would seek credit union input and follow similar development timelines in their future rulemaking projects. CUNA has recommended that the CFPB outreach effort include a separate interview panel comprised solely of credit union lending professional because--as not-for-profit cooperatives organized to promote thrift and make loans to members at reasonable rates of interest--credit unions are different from for-profit banks and non-depository mortgage lenders, as well as different from mortgage brokers. Use the resource link below for information on how to comment on the proposed combine disclosure form.
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