CFPB Proposes New Mortgage Disclosure Rules

On July 9, 2012, the Bureau of Consumer Financial Protection (CFPB) issued a proposed rule on mortgage disclosures (Proposed Rule) implementing requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  The Proposed Rule would create an integrated disclosure for mortgage loan transactions by combining the disclosures currently required under the Truth in Lending Act (TILA) (as implemented by the CFPB’s Regulation Z), with the disclosures currently required under the Real Estate Settlement Procedures Act (RESPA) (as implemented by the CFPB’s Regulation X).  It would also reconcile statutory differences between TILA and RESPA as necessary and incorporate new disclosures required by Congress under the Dodd-Frank Act.  The Proposed Rule introduces two new integrated mortgage disclosure forms: a Loan Estimate and a Closing Disclosure.