CMC Letter to CFPB Re Integration Rounds 4 and 5

Dear Mr. Date:

The Consumer Mortgage Coalition (CMC), a trade association of national mortgage lenders, servicers, and service providers, appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau (CFPB) on Round 5 of the “Know Before You Owe” prototype integrated mortgage disclosure forms. We continue to support the CFPB’s iterative approach to redesigning these important disclosures.

We want to begin this letter, though, by noting that the prototypes may not be well suited for the ways in which consumer shopping is adapting to modern technology. Recently, software available on mobile web access devices such as smartphones and tablets has streamlined the home and mortgage shopping process. This technology is evolving rapidly. With mobile devices, consumers can find detailed information about homes for sale, including those located near where the consumer is at the time of a search. Mobile devices can retrieve information about homes, their cost, price history, comparable sales nearby, current loan rates, and an approximate monthly loan payment. Consumers can retrieve information about estimated loan payments based on loan terms the consumer selects, and they can receive estimated property taxes and insurance. They can receive competing quotes from multiple lenders. Software can connect consumers to lenders or real estate agents with a click. Very detailed information is available by a few clicks long before a consumer ever approaches a lender and receives a Loan Estimate.1 The amount of information available to consumers will increase in the future.