CBA comments to CFPB Regarding Mortgage Loan Closing Process

Re: Request for Information Regarding the Mortgage Loan Closing Process – Docket No. CFPB – 2013- 0036 


Dear Ms. Jackson:

The Consumer Bankers Association (CBA) appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB’s) request for information on the mortgage loan closing process. Specifically, the CFPB is requesting information on key consumer “pain points” associated with mortgage closings and how these pain points may be addressed by market innovation and technology. This is the initial step in the CFPB’s next phase of its “Know Before You Owe” initiative with regard to mortgages, with the first phase being the development of the new combined TILA/RESPA disclosures that will become effective on August 1, 2015.

For this initial step in the process of collecting information on the mortgage loan closing process, the CFPB has requested comments on a number of specific questions. Below are CBA’s general comments on the mortgage closing process and the CFPB’s approach in reviewing this process, followed by responses to the specific questions posed by the CFPB.

General Comments
CBA and the banking industry certainly share the goal of improving the loan closing process for consumers and want to work closely with the CFPB as it embarks on this process. However, we have concerns with the timing of this process, the scope of the CFPB’s inquiries, and how the CFPB will use the information collected.


To read the full Comment Letter, please download the PDF.