"Know Before You Owe" Deadline Disclosure

In November of 2013, the CFPB issued its final rule to combine consumer TILA and RESPA disclosures for mortgage loans as required by the Dodd Frank Act. Early on in its existence, the Bureau made the combined "know before you owe" disclosures a focal point of its mortgage rulemakings, publishing a series of prototype disclosures for public comment beginning in 2011 and conducting multiple rounds of consumer testing. Rightly or wrongly, the CFPB believes that the new forms will provide better information in a clear format that will help consumers understand the terms and costs of the loan product being offered and allow for easier comparison shopping.

The new disclosure documents replace the initial and loan closing disclosures under TILA and the GFE and HUD-1 under RESPA and consist of two forms: (1) the Loan Estimate and (2) the Closing Disclosure. The Loan Estimate is designed to help consumers understand the key features, risks and costs of the mortgage loan for