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CFPB small biz review panel discussed disclosures more
WASHINGTON (3/7/12)--The Consumer Financial Protection Bureau (CFPB) conducted the first meeting of its small business review panel to discuss the bureau's recent work to integrate the Truth in Lending and Real Estate Settlement Procedures Act (RESPA) mortgage disclosure requirements.

The Small Business Regulatory Enforcement Fairness Act (SBREFA) panel, required by the Dodd-Frank Wall Street Reform and Consumer Protection Act,  is charged with seeking input directly from credit unions and other small financial service providers for any proposed rule that may have a significant economic impact on a substantial number of small providers.

The panel is comprised of representatives from the CFPB, the U.S. Small Business Administration (SBA), and the Office of Management and Budget. Representing credit unions during the forum were Lori Thompson, president of Premier FCU, Greensboro, N.C., Bernie Winne, CEO of Boston Firefighters CU, Boston, Mass., and Jeanne Kucey of JetStream FCU, Miami Lakes, Fla.

The panel discussion Tuesday involved topics including the prototype loan estimate and settlement disclosures developed by the CFPB through its Know Before You Owe mortgage disclosure project.

The review panel also discussed:
  • The definition of an "application" under RESPA to determine when a good-faith estimate under current rules is required to be generated and given to a consumer;
  • Certain re-disclosure requirements concerning loan-cost estimates,
  • Proposed recordkeeping and data collection requirements for lenders, and
  • The composition of annual percentage rate calculations under consideration by the bureau.
The bureau intends to issue a proposed combined mortgage disclosure rule in July.


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