Congress gave the CFPB a mandate to merge the RESPA and TILA forms and according to one top lender, the new bureau has spent a great deal of time trying to provide clear and informative disclosures for mortgage applicants.
“This is their baby,” said Kyung Cho-Miller, a JPMorgan Chase vice president and assistant general counsel.
“It’s one of the biggest things they can do for the consumer,” she told a National Mortgage News regulatory symposium late last week. Among all mortgage providers, JPM ranks second nationwide.
The comment period on merging the forms ends later this fall. A new form should be ready for public viewing early next year.
The Chase vice president noted that there are certain areas where bureau officials feel they cannot compromise. The proposed integrated RESPA/TILA form, which the CFPB calls the “Loan Estimate,” is designed to help borrowers shop for the best deal.
“There is a lot of evidence that by the time the borrowers get these disclosures they really aren’t shopping,” Cho-Miller said. Nevertheless, the bureau wants to make shopping easier for the “very small segment of the population” that comparison shops.
The agency will consider changes in some other areas and is “interested in feedback,” she said, particularly data. “Anything you have data on, they will take it. It helps them build a record.”
Cho-Miller is concerned that the CFPB has slimmed down the definition of an application too far, which could result in multiple redisclosures.
As proposed, six pieces of information will trigger the issuance of the “Loan Estimate” disclosure—applicant’s name, income, Social Security number, property address, estimate of property’s value and mortgage amount.
As the borrower figures out what they can afford and what loan product they want, it will trigger more disclosures. “In some cases, the borrower is going to get five or six disclosures before they get to closing,” she said.