Well, some of what we are dealing with is really our own fault. Of the people that have participated on this thread, how many of your institutions actually commented on the proposal in Aug 2012? or let alone read it? There were 2,921 comments submitted. I don't know how many banks or industry groups commented, but some of the comments included:
- Adding some color could help break up the sections. - Independent
- The more you guys get involved, the more confusinng it gets... I have been in the business almost 17 years. The new disclosures I can see my consumers eyes glaze over everytime I go over these new disclosures. I have to go over them 3-4 times, thye still usually dont get the logistics of it. Was much much easier for the consumer with a 1 page GFE. Learn how to put all this on 1 page and you will be much better. Will there be a day when we have a 150 page GFE to explain? - Landover Mortgage
- After review of your sample before and after disclosures, I feel they are an improvement. These should help clients understand the financing regardless of their background training. I especially appreciate the reduction in paper needed.Will you also help reduce the number of disclosures needed for a home loan? - American Pacific Mortgage
- I work at a small bank, and we have many customers that choose to use our current Balloon Loan Product, or their property may not qualify for secondary market financing, or the loan is small and closing costs would be too high to go secondary market. There are many situations that a balloon loan may be a better option for customers. Please consider to allow Balloon Loans. There are many banks that use Balloon Loans. - State Bank of Chilton
This is the quality of the comments the CFPB received. What did your letter say?
There were 6,110 commercial banks in the US at the time the proposal was out and the CFPB received very few significant comment letters on the actual substance of the disclosures, problems that their proposal would cause, areas where there was no guidance or the instructions were confusing, etc..
Maybe we can do better this time around?
The opinions expressed here should not be construed to be those of my employer: PPDocs.com