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April 23, 2012
On Friday, April 13, 2012 NAR and 11 other industry trade associations submitted a letter to the Director of the Consumer Financial Protection Bureau asking for an expanded rule-making process so that industry can properly evaluate the proposed RESPA/TILA harmonization. The industry wants to ensure that this rule is done right and does not harm consumers or the industries that serve them.
As forecast, the RESPA/TILA harmonization will be a major regulatory undertaking and many of the earlier RESPA reforms are being reviewed including the scope and rules relating to "tolerances." In some cases CFPB is asking for input on tightening rules and in others loosening rules. Also, there are many dilemmas facing CFPB on who should bare responsibility for completing settlement statements/ Truth in Lending (TIL) disclosure and the timing of issuing such documents.
Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, the CPFB is required to propose a regulation by July 21, 2012 and it is expected to do so, the industry groups would like it to be an advanced notice of proposed rule-making that will give industry two chances to comment on the proposal and seek needed changes. It will also give the CFPB the ability to integrate essential elements from the forthcoming QM and QRM rules into the forms and regulations.