CFPB seeks public input on mortgage disclosure rules

The CFPB is specifically soliciting comments on three key areas: the integrated mortgage disclosures mandated by the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA), commonly known as TRID; the right of rescission applicable to certain refinance transactions; and the disclosure requirements pertinent to reverse mortgages.

The bureau is inquiring whether the existing rules impose unnecessary burdens while still offering adequate consumer protections. Specific aspects under consideration include the timing of disclosures, tolerance thresholds, the use of electronic disclosures, and the potential for developing more tailored rules for smaller financial institutions.

Regarding reverse mortgages, the CFPB noted that current disclosures involve multiple documents. It is seeking feedback on whether a consolidated set of integrated disclosures, designed specifically for reverse mortgages, would be more beneficial for borrowers. The agency is also reviewing the Total Annual Loan Cost (TALC) disclosure for reverse mortgages, asking whether its calculations should be updated and if presenting projected loan balance growth in dollar amounts would be more understandable than current annualized cost figures.

Furthermore, the CFPB is exploring whether reverse mortgage borrowers would benefit from educational materials tailored to their specific product needs, as opposed to the general mortgage information currently required. While this RFI does not propose any concrete regulatory changes, the collected comments will be instrumental in determining the appropriateness of future rulemaking.