The Federal Register published the proposed rule on August 23, 2012.

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1 CFPB Issues Draft RESPA-TILA Proposed Rules On July 9, the Consumer Financial Protection Bureau ( Bureau or CFPB ) released draft proposed rules and model forms that combine the required disclosures under the Truth In Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA). These proposed rules are issued pursuant to sections 1032(f), 1098 and 1100A of the Dodd-Frank Wall Street Reform and Consumer Protection Act, where Congress requires that CFPB publish a single, integrated disclosure for mortgage loan transactions that satisfies the requirements of both RESPA and TILA. This summary omits much of the technical description regarding the full range of disclosure blocks and fields that are contained in the proposed merged forms. For a complete understanding of the breadth of this rulemaking, this summary should be reviewed in connection with the actual proposed forms, which can be found at The Federal Register published the proposed rule on August 23, Comment Due Dates The comments for this rulemaking are bifurcated. For those elements under 12 CFR (c) (dealing with the delay of various statutory requirements imposed by Dodd-Frank) and (dealing with the revised definition of finance charge ), comments must be received on or before September 7, For all other sections, comments must be received on or before November 6, Dates and Deadlines The Dodd-Frank Act required the CFPB to propose integrated RESPA and TILA disclosures by July 21, The Act did not, however, impose a deadline for the issuance of a final rule regarding the merged forms. CFPB believes the final rule will provide important benefits to consumers, and therefore seeks to make it effective as soon as possible. The Bureau understands, however, that the final rule will require extensive system revisions and retraining of staff. The Bureau is seeking comment on when this final rule should become effective. In this sense, the Bureau expects that it may take some time to conduct quantitative testing of the forms prior to issuing final rules. Moreover, the Bureau recognizes that entities will be required to implement numerous other Dodd-Frank Act provisions, which are subject to separate rulemaking deadlines and separate effective dates. The draft notice proposes to delay compliance with new requirements that would add to or affect the RESPA-TILA disclosures covered by this rule. The Bureau opines that both consumers and industry would benefit if all relevant disclosures are implemented in a coordinated manner. The Bureau will issue a final rule finalizing the proposed delay prior to January 21, The following statutory provisions will be delayed under this process: Warning regarding negative amortization features (section 1414(a)); Disclosure of State law anti-deficiency protections (section 1414(c)); Disclosure regarding creditor s partial payment policy (section 1414(d)); Disclosure regarding mandatory escrow accounts (section 1461(a)); Disclosure regarding waiver of escrow at consummation (section 1462; Disclosure of monthly payment, including escrow, at initial and fully-indexed rate for variable-rate transactions (section 1419); Repayment analysis disclosure to include amount of escrow payments for taxes and insurance (section 1465); Disclosure of settlement charges and fees and the approximate amount of the wholesale rate of funds (section 1419); Disclosure of mortgage originator fees 1

2 (section 1419); Disclosure of total interest as a percentage of principal (section 1419); Optional disclosure of appraisal management company fee (section 1475). CFPB is planning to implement the listed statutory changes together with the adoption of the final integrated disclosure forms. As had been requested by ABA, this coordinated approach will avoid requiring the industry to modify the existing disclosure forms to incorporate the Dodd- Frank Title XIV changes, and then shortly thereafter replace the forms with the integrated disclosure forms. Scope & Coverage The Rules generally cover closed-end mortgage loans and exclude: Home-equity lines of credit, Reverse mortgages, Mortgages secured by a mobile home or by dwellings not attached to real property; Loans by creditors that make five or fewer mortgages in one calendar year. The Loan Estimate The draft Rules propose to replace the Good Faith Estimate (under Regulation X) and the early Truth in Lending disclosure (under Regulation Z). Detailed instructions on completing the Loan Estimate are set forth in the proposed rule and new Official Interpretations. The highlights are as follow The Loan Estimate must be provided no later than three (3) business days after a consumer submits a loan application. In addition, these disclosures must be delivered not later than the seventh business day before consummation of the transaction. The Loan Estimate may be provided by either the broker or the lender, but the lender remains responsible for the accuracy of the form. The creditor may not impose a fee on a consumer in connection with an application (other than a fee to obtain a credit report) until the consumer has received the Loan Estimate and has affirmatively indicated an intent to proceed with the transaction. The proposal would allow lenders to offer pre-application estimates. The Bureau is proposing to require that any pre-application, consumer-specific written estimate of loan terms or settlement charges contain a prominent disclaimer indicating that the document is not the Loan Estimate required by TILA and RESPA. This requirement would not apply to general advertisements. Application The Bureau is proposing to add (a)(3)(i) to define application as the submission of a consumer s financial information for the purposes of obtaining an extension of credit. Specifically, under the proposal, application is defined as the submission of (1) the consumer s name, (2) income, (3) Social Security number to obtain a credit report (or other unique identifier 2

3 if the consumer has no Social Security number), (4) the property address, (5) an estimate of the value of the property, and (6) the mortgage loan amount sought. The proposal eliminates current rule under Regulation X that permits lender to require any other information deemed necessary before triggering the issuance of a GFE. The proposed Official Interpretations clarify that the creditor may ask for additional information, but in any event, the receipt of the six listed pieces of information would trigger the obligation to provide the Loan Estimate. Business day means all calendar days except Sundays and the legal public holidays specified in 5 U.S.C. 6103(a), i.e., New Year s Day, the Birthday of Martin Luther King, Jr., Washington s Birthday, Memorial Day, Independence Day, Labor Day, Columbus Day, Veterans Day, Thanksgiving Day, and Christmas Day. The Bureau proposes that a creditor shall not require a consumer to submit documents verifying information related to the consumer s application before providing the Loan Estimates disclosures. The Closing Disclosure The draft proposal would require that a Closing Disclosure must be provided to the consumer before the consumer closes on a covered mortgage loan. The proposed rule and the Official Interpretations (on which lenders can rely) contain detailed instructions as to how each line on the Closing Disclosure form would be completed. The consumer must receive this Closing Disclosure form at least three business days before the consumer closes on the loan. Generally, if changes occur between the time the Closing Disclosure form is given and the closing, the consumer must be provided a new form. When that happens, the consumer must be given three additional business days to review that form before closing. The proposed rule contains certain exemptions from the three-day requirement for some common changes. These include changes resulting from negotiations between buyer and seller after the final walk-through. There also is an exception for minor changes which result in less than $100 in increased costs. The Bureau is proposing two alternatives for who is required to provide consumers with the new Closing Disclosure form. Under the first option, the lender would be responsible for delivering the Closing Disclosure form to the consumer. Under the second option, the lender may rely on the settlement agent to provide the form. (Under second option, lenders remain responsible for the accuracy of the form.) The Rule sets forth the Closing Disclosure as a model form, and includes various versions of the form for different loan types and transactions (including modifications of the Closing Disclosure for transactions that do or do not include sellers). 3

4 The Proposal would prohibit creditors from providing a consumer with disclosures of estimated and final costs at the same time. The Rule would therefore prohibit that a consumer receive a revised Loan Estimate disclosure, or a Changed Circumstances redisclosure, on the same business day as the consumer receives the Closing Disclosures. Tolerances and Restrictions on Cost Increases The proposed rule would restrict the circumstances in which consumers can be required to pay more for settlement services than that which was originally stated on the Loan Estimate form. As with existing law, lenders may revise the disclosures of the initial Loan Estimate form only if there are valid changed circumstances. The Rule would apply the cost tolerances are as follows Unless an exception applies, charges for the following services may not increase: (1) the lender s or mortgage broker s charges for its own services; (2) charges for services provided by an affiliate of the lender or mortgage broker; and (3) charges for services for which the lender or mortgage broker does not permit the consumer to shop. Unless an exception applies, charges for most other services generally could not increase by more than 10 percent. Certain other charges may exceed the amounts disclosed on the Loan Estimate if estimate is consistent with the best information available to the creditor at the time it is disclosed. These charges include prepaid interest; property insurance premiums; amounts placed in escrow, impound, reserve, or similar accounts; and charges paid to third-party service providers that are selected by the consumer but are not disclosed on the written list of service providers provided by the creditor. Changed Circumstances: For purposes of determining good faith, a charge paid by or imposed on the consumer may exceed the originally estimated charge if the disclosures are revised and redisclosed to the consumer, and the revision is caused by specific reasons identified in (e)(3)(iv)(A) through (F). These reasons include An extraordinary event beyond the control of any interested party or other unexpected event specific to the consumer or transaction, Information specific to the consumer or transaction that the creditor relied upon when providing the disclosures and that was inaccurate or subsequently changed, New information specific to the consumer or transaction that was not relied on when providing the disclosures, or changes in circumstance affecting the consumer s creditworthiness or the value of the collateral causes the estimated charges to increase. 4

5 Borrower requests changes to the mortgage loan identified in the GFE that change the settlement charges or the terms of the loan. Changes to interest rate dependent charges when interest rates change. Valid reason for reissuance exists when a consumer expresses an intent to proceed more than ten business days after the initial disclosures are provided. Disclosures for construction loans where consummation will not occur until well into the future, likely after construction is completed, provided that the consumer is aware of this fact. This proposed definition omits one prong of the existing definition, which provides that: [o]ther circumstances that are particular to the borrower or transaction, including boundary disputes, the need for flood insurance, or environmental problems is considered a changed circumstance. The applicable TILA tolerances set forth in (d)(1) would generally continue to apply to closed-end transactions. Changes After Delivery of Closing Disclosure For changes in terms in the transaction after delivery of the Closing Disclosure, the proposal provides that creditor must deliver a revised Closing Disclosure reflecting the changed terms, and the consumer must be given three additional business days to review that form before closing. However, the proposed rule contains exceptions from the three-day requirement for some common changes: Changes resulting from negotiations between the consumer and seller, A change in the amount actually paid by the consumer that does not exceed $100, Revised cost disclosures in connection with administrative or other inaccuracies resulting from payments to a government entity (i.e., locality could change its schedule of recording fees) must be delivered no later than the third business day after the event occurs, and no later than 30 days after consummation. Revised disclosures for non-numeric clerical errors must be disclosed as soon as reasonably practicable, but no later than 30 days after consummation. Finance Charge & All-In APR The Bureau is proposing to exclude the finance charge disclosure from the Loan Estimate form, stating that this effectuates the purposes of TILA by avoiding consumer confusion and information overload. The Bureau proposes to preserve the finance charge disclosure on the Closing Disclosure provided to consumers at least three days prior to prior to consummation. 5

6 The CFPB is proposing to replace the current definition of finance charge under TILA with simpler, more inclusive test. Under the proposal, a fee or charge would be included in the finance charge amount if: (A) it is payable directly or indirectly by the consumer to whom the credit is extended; and (B) it is imposed directly or indirectly by the creditor as an incident to or a condition of the extension of credit. The proposal largely eliminates the current exclusions from the finance charge for closed-end transactions secured by real property or a dwelling. The proposed definition of finance charge for closed-end mortgage transactions would include All items currently included in the definition; Closing agent charges, The so-called.4(c)(7) charges that are currently excludable from the finance charge, Credit life insurance premiums, Voluntary debt cancellation fees, and Security-interest charges. The Bureau s proposal would continue to exclude Fees or charges paid in comparable cash transactions, Late fees and other similar default or delinquency charges, Seller s points, Amounts required to be paid into escrow accounts (if they would not otherwise be included in the finance charge), Premiums for property and liability insurance if certain conditions were met. The Bureau recognizes that the more inclusive finance charge will cause more loans to be considered higher-priced mortgage loans and would expand the coverage of HOEPA and similar State laws. The CFPB also expressed awareness that a more inclusive finance charge has implications for the Appraisals, Ability to Repay, and Escrow rulemakings identified above. The Bureau states that it is carefully weighing whether modifications may be warranted to the thresholds for particular regulatory regimes (HOEPA and HPML) to approximate coverage levels under the current definition of finance charge. 6

7 The CFPB is seeking comments on two different methods of reconciling the expanded definition of the finance charge with existing APR or points-and-fees triggers. The Bureau is specifically seeking comments on this topic by the earlier September 7, 2012 date. The two options offered by the Bureau are as follow As per the Federal Reserve Board s previous proposals on this matter, the Bureau would replace the APR with a transaction coverage rate as a transaction-specific metric a creditor compares to the average prime offer rate to determine whether the transaction meets the higher-priced loan threshold. Under this approach, lenders would have to calculate one metric for purposes of disclosure and another for purposes of regulatory coverage. (For a more detailed description of this approach, see 76 FR 27390, (May 11, 2011); 76 FR 11598, (Mar. 2, 2011); 75 FR 58539, (Sept. 24, 2010)). Retain the existing treatment of certain charges in the definition of points and fees for purposes of determining HOEPA coverage. The Bureau has proposed language to adopt the transaction coverage rate and to exclude the additional charges from the HOEPA points and fees test in its 2012 HOEPA Proposal. (For a more detailed description of this approach, see 75 FR 58539, (Sept. 24, 2010)). The Bureau also intends to develop supplemental educational materials in booklets and its website that will further explain how the APR differs from the interest rate, how it provides a good way of comparing the entire costs of the loan over the entire term, and why consumers may want to use both the In 5 Years and APR figures to think about their financial futures. The Bureau seeks comments on the impact of this change across all affected regulations, and believes that it is also helpful to analyze potential mitigation measures on a rule-by-rule basis. Other Items Average Cost Pricing: The Bureau is proposing provisions to clarify that a creditor or settlement service provider may charge a consumer or seller the average charge for a settlement service if the average charge is no more than the average amount paid for that service by or on behalf of all consumers and sellers for a class of transactions, the creditor or settlement service provider defines the class of transactions based on an appropriate period of time, geographic area, and type of loan, the creditor or settlement service provider uses the same average charge for every transaction within the defined class, and the creditor or settlement service provider does not use an average charge for any type of insurance, for any charge based on the loan amount or property value, or if doing so is otherwise prohibited by law. An average-charge program may not be used in a way that inflates the cost for settlement services overall. 7

8 If a creditor chooses to use an average charge for a settlement service for a particular loan within a class, then the creditor must use that average charge for that service on all loans within the class. The average charge must be calculated according to the average amount paid for a settlement service in a prior period, and updates to the average charge may be delayed for an amount of time sufficient to re-calculate the average charge, provided that such delays are applies uniformly from one time period to the next. The Bureau seeks comments on permitting adjustments to the average charge based on prospective analysis are where the creditor or settlement service provider develops a statistically accurate and reliable method for doing so. Amount Financed: The Bureau proposes to exclude disclosure of the amount financed from the Loan Estimate forms, opining it effectuates the purposes of TILA by avoiding consumer confusion and information overload historically associated with the disclosure. Disclosure of Total Interest Percentage: The Bureau proposes to implement Dodd-Frank additions to TILA requiring creditors to disclose the total interest percentage, using that term and the abbreviation TIP, and requiring creditors to disclose the descriptive statement The total amount of interest that you will pay over the loan term as a percentage of your loan amount. Recordkeeping The total interest percentage is the total amount of interest that the consumer will pay over the life of the loan, expressed as a percentage of the principal of the loan. When calculating the total interest percentage, the creditor must assume that the consumer will make each payment in full and on time, and will not make any additional payments. For adjustable-rate mortgages, (1)(3) requires that the creditor compute the total interest percentage using the fully-indexed rate and that, for step-rate mortgages the creditor is to compute the total interest percentage in accordance with specific provisions set forth in the commentary. For loans that permit negative amortization, (l)(3) requires that the creditor is to compute the total interest percentage using the minimum payment amount until the consumer must begin making fully amortizing payments under the terms of the legal obligation. The proposed rule requires creditors to keep records of the Loan Estimate and Closing Disclosure delivered to consumers in a standard electronic, machine-readable format. Evidence of the Loan Estimate must be retained for three years after the later of the date of consummation, the date disclosures are required to be made, or the date the action is required to be taken. Evidence of the Closing Disclosure must be retained for five years after consummation. 8

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