From Bad To Worse?
The CFPB released round 3 of its Settlement Disclosure Form, Butternut and Hemlock. The Bureau is asking the public to do something different this time around. Instead of just comparing the two versions of the same disclosure, they are asking the public to comment on how a draft closing stage form works with the draft application stage form. This round of the project will be tested in the Philadelphia, PA. The Bureau seems to be focusing on industry’s concerns over how the form ties to the GFE replacement form and how we would complete these forms in our current systems. Please be sure to think about that aspect as your consider these forms, and note that The Bureau is asking for comments via email to KnowBeforeYouOwe@cfpb.gov or their blog postings, rather than just a simple noted preference for one version over the other. This is where our voice becomes more critical, as they begin to narrow the scope down to very practical matters.
Click here to see Hemlock (SDF version 5)