Advocacy Comments on Proposed Mortgage Disclosure Regulations

On November 6, the Office of Advocacy submitted comments to the Consumer Financial Protection Bureau on the proposed rule on Integrated Mortgage Disclosures under the Real Estate Settlement Procedures Act (“RESPA” or Regulation X) and the Truth in Lending Act (“TILA” or Regulation Z). The rule governs the practices and documents in use when consumers close on real estate loans.

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Advocacy has held several roundtables to listen to the concerns of small community banks regarding the proposed regulation. Their five top issues concern the costs from the expanded recordkeeping requirements, the difficulties of integrating the two mortgage disclosure statements used under the previous system, problems arising from the revised definition of the term “loan application,” the burden of requiring three days for the presumed receipt of documents, and confusion arising from defining Saturday as a business day.

All of these concerns are perceived as roadblocks to mortgage lending by small community banks. To alleviate their impact on small business while maintaining the rule’s purpose, Advocacy recommended that CFPB allow for flexibility in small business compliance with the regulation, delaying the effective date of one measure, providing an exemption from another, and specific modifications of others. For complete information, see Advocacy’s letter of November 6. The details are also spelled out in a fact sheet on Advocacy’s website.

If you have any questions regarding Advocacy’s position on this issue, please do not hesitate to contact Jennifer Smith at 202-205-6943. For more information about the Office of Advocacy, please visit our website  or telephone 202-205-6533. To receive Advocacy’s Regulatory Communications by email, visit

—Rebecca Krafft, Editor


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