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ICBA Issues Statement on CFPB Mortgage Disclosure Forms

Washington, D.C. (Nov. 20, 2013)—The Independent Community Bankers of America® (ICBA) said it is pleased that the Consumer Financial Protection Bureau (CFPB) incorporated suggestions from ICBA and the community banking industry in the mortgage-lending disclosure forms released today. The rule will combine two critical mortgage-loan and property-settlement disclosures that will affect virtually all consumer real estate transactions. ICBA noted that the 1,888-page final rule is extremely long and complex and expressed its appreciation for the extended implementation date of Aug. 1, 2015.

“While ICBA maintains some concerns with the size and complexity of this final rule, which the association continues to examine closely, the CFPB has clearly heeded many of the community banking industry’s feedback on these new disclosure forms,” ICBA President and CEO Camden R. Fine said. “ICBA and the nation’s community banks repeatedly have provided comments on the forms throughout the rulemaking process and look forward to continuing this dialogue with the CFPB as it implements this rule.”

ICBA said the model Loan Estimate and Closing Disclosure forms are clearer than existing disclosures and should be easier for consumers to understand. Further, the association applauds the CFPB’s decision not to move ahead with its proposed drastic revision of the Annual Percentage Rate calculation, which would have disrupted the housing and mortgage markets and raised costs for consumers seeking to obtain mortgage loans.

ICBA also said it is pleased that the CFPB dropped its proposal to require mortgage lenders to maintain copies of the Loan Estimate and Closing Disclosure forms in machine-readable form, which would have required a massive and expensive retooling of lenders’ document-storage systems. Finally, while the association is concerned that the new requirement to deliver the Closing Disclosure form to borrowers within three business days prior to settlement could result in delays and cost increases, it recognizes that the bureau has sought to minimize this risk by providing some tolerances for minor changes that would not delay closings.

ICBA looks forward to working with the CFPB as it implements the rule and hopes the bureau continues to involve community bankers in future rulemakings.

For more information, visit www.icba.org.

About ICBA
The Independent Community Bankers of America®, the nation’s voice for nearly 7,000 community banks of all sizes and charter types, is dedicated exclusively to representing the interests of the community banking industry and its membership through effective advocacy, best-in-class education and high-quality products and services. For more information, visit www.icba.org.

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