“We believe such deferral should last until after the RESPA-TILA integrated disclosure rule is implemented and its effects on the process can be fully appreciated. We believe it makes more sense to wait until after the new rule is fully implemented before delving further into the closing process. The rule introduces a completely new disclosure regime accompanied by extensive rules, which include limits on closing cost increases, key changes to disclosure responsibilities and a new 3 day waiting period between closing disclosures and closing.”
The groups added that banks have had less than 10 weeks since the 1,800-page RESPA-TILA rule was issued, during which time the CFPB’s suite of mortgage rules -- including Ability-to-Repay/Qualified Mortgage -- took effect. The month-long comment period for the RFI was thus insufficient, the groups said, adding that “we believe rethinking the next stage of Know Before You Owe in light of the RESPA-TILA rule is essential to ensure a meaningful effort.”
Read the letter.