Removing Barriers Blog

CFPB Announces Finalized Rule & Proposed Rule for Mortgage Disclosures
Posted July 07, 2017 by CUNA Advocacy

The Consumer Financial Protection Bureau (CFPB) announced its finalized updates to the “Know Before You Owe” mortgage disclosure rule.   The changes are intended to formalize guidance and provide greater clarity and certainty.   

The underlying disclosure rule originally went into effect in October of 2015.  According to the CFPB, these amendments address issues with the original rule and also include clarifications and technical corrections. 

CUNA is currently in the process of reviewing the changes made to the rule and the effects they will have on credit unions and their members.  Compliance with the amendments will need to be in effect by October 1, 2018. 

In addition to amending the “Know Before You Owe” mortgage rules, the CFPB also issued a proposal to address mortgage disclosure requirements under TILA/RESPA Regulation Z.  The proposed amendments relate to when a creditor may compare charges paid by or imposed on the consumer to amounts disclosed on a Closing Disclosure, instead of a Loan Estimate, to determine if an estimated closing cost was disclosed in good faith. 

CUNA will be submitting written comments later this summer -- comments on the rule will be due 60 days after the proposed rule is published in the Federal Register, which is expected shortly.