Comments are due Wednesday, August 10, for Round 3 of the CFPB’s “Know Before You Owe” project, the result of which will be a new, combined Truth in Lending/RESPA mortgage disclosure form.
The CFPB presents the two new forms, named Azalea and Camellia, on its web site and asks consumers and industry participants to effectively “vote” for one of the two.
To provide feedback:
- Go to the CFPB web site’s “Know Before You Owe” page.
- Click on either the Azalea or Camellia form.
- You’ll then be taken to a page that says, “We would like to know more about why you chose this form. Click to indicate which four items you would highlight to your customer to compare with another lender’s form.” You may add up to four notes before sending.
- You may also then comment on the form that you did not select.
- You will to answer two additional questions about the form, have the opportunity to provide comments, and be asked for your ZIP code and occupation (optional).
Anyone may also comment on the features of one or both forms by posting a comment on the CFPB blog, or by submitting a letter to the CFPB:
Bureau of Consumer Financial Protection
1801 L Street, N.W.
Washington, D.C. 20036
This is Round 3 of an expected five rounds of comment-taking and testing, with a final prototype to be released to the public this fall.
“These prototypes are still early in the design phase. The numbers that appear on the forms are designed to comply generally with the existing regulations under TILA and RESPA, but we have made adjustments as necessary to enable us to test certain elements with consumers. For example, in Round 3 (Azalea and Camellia), the fee detail does not include language about tolerances. This allows us to focus on the design on this round. We will work on consumer understanding of tolerances in later rounds,” CFPB staff wrote online.
In past rounds, financial services industry groups and software vendors have commented that although the design of the CFPB prototypes is attractive, the forms would be difficult to program and reproduce.
For information on other proposed rules open for comment, see the CFPB’s Notice and Comment web page.