The Consumer Financial Protection Bureau announced a final rule to clarify the TILA/RESPA Integrated Disclosure requirements. The rule finalizes many of the CFPB's earlier proposals, some with modifications. However, the agency still has not formally addressed important issues (like a lender's ability to cure errors and the disclosure of title insurance premiums where a simultaneous discount applies), and it offers a new proposal to address the "black hole" on resetting fee tolerances. The final regulations will take effect 60 days after publication in the Federal Register.
Mayer Brown's Legal Update discusses the CFPB's latest attempt to strike a balance between the disclosure burdens on lenders or closing agents and ensuring consumers receive clear and useful information.
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