Proposed mortgage lending documents from the Consumer Financial Protection Bureau could create operational issues for lenders, the Mortgage Bankers Association said in a letter to the CFPB this week. Stephen O’Connor, senior vice president of public policy for the MBA, sent a letter to CFPB architect Elizabeth Warren, saying the “MBA is concerned that the prototypes may be difficult if not impossible for many lenders to operationalize using existing systems. Many systems are incapable of providing a double-sided disclosure.” In his letter, O’Connor directly addresses concerns the industry has over the latest mortgage disclosure prototypes introduced by the CFPB. It’s the second set of prototype documents released by the CFPB in the past two months. Even though the CFPB’s goal is to combined the Truth in Lending Act and Real Estate Settlement Procedures Act forms into one document, the MBA says the prototype forms, in their current state, conflict with TILA and RESPA requirements. The trade association also claims the front page of the documents are confusing because the “values for monthly loan payment and projected payment do not match because estimates taxes and insurance are included in the latter.” In his letter, O’Connor requested an in-person meeting between the CFPB and industry professionals to address some of the MBA’s concerns. “A meeting at this point could provide lenders a better understanding of the direction of the project so they could offer more informed comments and offer stakeholders an opportunity to explain challenges under RESPA and TILA and the practical concerns posed by the current prototypes,” O’Connor wrote. Write to Kerri Panchuk.
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