ABA has spearheaded the industry’s efforts to gain greater clarity on the rule, hosting several compliance working groups to discuss the rule’s effects and identify aspects of the rule that could be clarified or amended.
In a recent joint letter to the CFPB, ABA and others urged the CFPB to issue formal guidance, and pointed out several compliance and interpretive questions that still need to be addressed, including the proper corrections to closing disclosures based on unforeseen circumstances; faulty instructions that do not always yield correct costs to close; principal reductions and lender credits; illustrating appropriate disclosures for construction loans; clarifying the coverage of cooperative share loans; and resolving conflicts between model forms and text.
ABA President and CEO Rob Nichols welcomed Cordray’s responsiveness. Nichols said:
The agency’s interim steps and guidance efforts are welcome, and we agree that several issues will be best resolved in the rule-making process that is being initiated. We are particularly pleased that the notice for proposed rulemaking is on a fast track, which will accelerate and strengthen strong compliance regimes.Read the joint trades letter.
Read Cordray's letter.