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Wednesday, November 12, 2014

ABA Suggests Improvements to TILA-RESPA Proposal

The CFPB’s proposed amendments to the TILA-RESPA mortgage disclosures should provide creditors more time — three days instead of one, as proposed — to issue revised disclosures after locking in a customer’s interest rate, ABA told the bureau in a comment letter.

ABA expressed appreciation for the proposal to relax timing requirements but explained why a 24-hour turnaround would be very difficult. ABA also offered technical suggestions regarding another aspect of the proposal, which would add language to the Loan Estimate informing construction borrowers that they might receive a revised Loan Estimate if their loan takes more than 60 days to settle.

Read the letter.

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