Joint Letter Re Need to Consider Rules With Forms
Dear Director Cordray:
We, the undersigned organizations, are writing to urge you to adopt an expanded rulemaking process in the Consumer Financial Protection Bureau's (Bureau) very important work to synchronize and simplify disclosures and forms required by the Real Estate Settlement Procedures Act (RESPA) and the Truth in Lending Act (TILA).
We appreciate the efforts the Bureau has made to make the combining and streamlining of the forms an open process. The regular give-and-take between the Bureau, industry, and the public has been positive and holds the promise of better, more thoughtful, forms.
At this point in the process, however, it is becoming clear that the accompanying rules that will govern the use and application of these forms are every bit as important as the content of the forms themselves. Among other things, the rules will govern the timing and reliability of the forms and provide remedies for misdisclosure. Notwithstanding, no input on these rules has been invited. For this reason and to ensure a more workable proposal, we encourage you to use a similarly open and interactive process to arrive at the accompanying rules.