State and federal disclosure differences could be a challenge as U.S. regulators continue to work toward improving the Good Faith Estimate and consumers' understanding of it.
“One of the unknowns is that this is clearly a federal program and many of the states have had their own independent disclosure requirements,” Ghazale Johnston, senior executive, Accenture Credit Services, told this publication.
This could be confusing for consumers, she said.
Under the Dodd-Frank Act, federal regulators are slated to improve consumers' understanding of the form by combining it with the Truth in Lending disclosure so that the two become a single form.
Under Dodd-Frank's timeline, the Consumer Financial Protection Bureau is supposed to implement regulations by related to these combined forms by July. It has been soliciting comments on prototypes that are accessible through its website.
