The Consumer Financial Protection Bureau (CFPB) has released the third of an expected five rounds of draft mortgage disclosure reform proposals for public comment.
After announcing their review of the second round of draft forms, round three of the effort to combine the Good Faith Estimate and Truth in Lending mortgage disclosures focuses on the design of the forms, especially as it relates to how the fees are presented. The issue of discussing tolerances is not presented in this round with the CFPB stating that later rounds will focus on consumer understanding of the tolerances related to fees that change between application to funding.
As with the previous two rounds, the CFPB presents two competing options for people to review and comment on, selecting their preference between the two forms.
Option "Azalea" Option "Camellia"
Both draft forms provide a categorization of fees into origination charges, services you can and cannot shop for, taxes and government fees and on-going costs (taxes and insurance). However, "Azalia" summarizes each category into general totals, whereas "Camellia" provides for a more itemized list of fees under each category.
Consumers and industry participants only have until Monday, August 8th to review the draft forms and provide comment to the CFPB. Details on the disclosure reform process can be found on the bureau's "Know Before You Owe" web pages.