On September 12, 2011, the Consumer Financial Protection Bureau (CFPB) released two new draft designs for a combined RESPA/TILA Disclosure Form and asked for feedback. The CFPB is attempting to combine the Truth in Lending Act (TILA) disclosures and RESPA's Good Faith Estimate (GFE). Visitors to the CFPB web posting can view the two forms and submit comments.
These newest forms, called "Jasmine" and "Nandina," deal with a refinance transaction. Jasmine is a 30-year loan with an adjustable rate that can adjust every year, starting in year eight. Nandina is also a 30-year loan, with an adjustable rate that can adjust every three years, starting in year four.
The CFPB intends to visit cities across the country to test the draft disclosure forms. During these visits the CFPB will interview consumers, lenders, and brokers about what they find helpful or confusing in the draft designs. After five rounds of this testing, and with input online, the CFPB will consult with other regulators and small businesses, and then issue a proposed rule. The public will then be given a further opportunity to submit written comments.
CATIC® will continue to monitor the situation and advise you of any significant updates.
Contact: Rich Hogan