CFPB has issued a proposal to amend Federal mortgage disclosure requirements under the Truth in Lending Act and the Real Estate Settlement Procedures Act (TILA-RESPA) that are implemented in Regulation Z. The proposed amendments relate to when a creditor may compare charges paid by or imposed on the consumer to amounts disclosed on a Closing Disclosure, instead of a Loan Estimate, to determine in an estimated closing cost was disclosed in good faith. Specifically, the proposed amendments would permit creditors to do so regardless of when the Closing Disclosure is provided relative to consummation. The proposal is intended to address what is referred to as the “black hole” issue that exists under the current TILA-RESPA rule. Comments are due 60 days after the proposal’s date of publication in the Federal Register.
View the proposal here.