Given all the mortgage reforms that are currently pending in the regulatory pipeline, ABA doubts that this RESPA-TILA proposal can properly accommodate all the changes that remain in tentative form. Too many issues require resolution in these major impending rulemakings, and individually, their final configuration can alter mortgage lending practices in fundamentally important ways. To ensure proper implementation of all the reform initiatives, ABA requests that the Bureau pause this rulemaking…Read the full comment letter.
Wednesday, November 7, 2012
ABA on CFPB's RESPA-TILA Proposals
ABA filed a comment letter to the CFPB regarding the proposed rules that would amend the mortgage shopping disclosures under Regulation Z, which implements the Truth in Lending Act (TILA), and Regulation X, which implements the Real Estate Settlement Procedures Act (RESPA).