Once the Consumer Financial Protection Bureau finalizes several mortgage rules in January, the bureau should be prepared to provide timely guidance on implementation issues, according to three industry groups.
“While guidance is always appreciated, because of the number of rules pending and the fact that they are moving so quickly, the need for substantial additional guidance after the rules are final will be unparalleled,” according to the American Financial Services Association, Consumer Mortgage Coalition, and Mortgage Bankers Association.
The CFPB is slated to issue final rules in January that define a qualified mortgage, establish new standards for servicers, and merge the RESPA and TILA loan disclosures.
Before the implementation period begins, industry and stakeholders should be given time to review the rule, ask questions and receive written answers. CFPB “should ensure that guidance is clear, useful and developed in an interactive process that involves all stakeholders,” the industry groups stress in a comment letter.
The three trade groups also want the bureau to follow up on the rulemaking by analyzing their cumulative impact on consumers.
If mortgage lenders implement numerous rules that contain “ambiguities not addressed by timely guidance, costs to consumers may rise and some providers may leave the marketplace, reducing competition. The net result will not benefit consumers,” the groups say in their comment letter.