Troutman Sanders CFPB Team
In what has become one of the Consumer Financial Protection Bureau's (CFPB) signature regulatory
initiatives - "Know Before You Owe" - the CFPB announced on July 28, 2011
that it would be conducting its third round of public commenting and consumer
testing on the proposed two-page Real Estate Settlement Practices Act("RESPA")
and Truth in Lending Act ("TILA") mortgage disclosure forms.
The first round of mortgage disclosures created front
page "shopping sheets" designed to allow consumer to compare key terms across mortgage
products. The CFPB released the first round of disclosures on May 18,
2011 to an overwhelming public response generating more than 13,000
The second round of public commenting and consumer
testing was limited to comparing two closing cost prototypes comprising the
second page of the form which would disclose all relevant information
concerning fees and closing costs. The CFPB received nearly 5,000
comments on the second round of public commenting.
The third round of public commenting and consumer testing
incorporates input from the first two rounds of consumer testing and public
commenting creating a revised, two-page disclosure form. According to the
CFPB's "Know Before You Owe" announcement, three major changes will be
incorporated into the third round of disclosures:
The CFPB's announcement for its third round of public
commenting and consumer testing on the RESPA/TILA disclosure can be read here. Unlike the first and second rounds of
sample forms, the third round of forms will be emailed to interested parties
who sign up on the CFPB's "Know Before You Owe" webpage.
Read more at Consumer Financial Protection Bureau
Report by Troutman Sanders LLP.
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