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Compliance: Don't relax, escrow disclosures are still coming
WASHINGTON (1/22/13)--For those of you who have been dancing around your offices since the final escrow rule was issued by the Consumer Financial Protection Bureau because the proposed escrow disclosures were missing--your dance party will probably be short-lived, the compliance team at the Credit Union National Association warns.

As the CFPB notes several times in the "Supplementary Information" to the rule, the disclosure provisions will not be adopted "in this rule."  [Emphasis added]. 

As you may remember, last November, the CFPB published a rule that "delayed implementation of certain new mortgage disclosures".  The purpose of the delay is to give the industry extra time so that the "entire TILA-RESPA disclosure regime" can go into effect at once. The "TILA-RESPA disclosure regime" includes the proposed escrow disclosures.

So, although the final escrow rule issued last week, which takes effect June 1, only includes the amended definitions of "higher-priced mortgage loan" and "escrow accounts", expect to see the escrow disclosures show up in a final rule later this year.
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