Treasury Unveils Sample RESPA-TILA Combined Disclosure

The recently enacted Dodd-Frank Wall Street Reform and Consumer Protection Act (H.R. 4173; P.L. 111-517) contains a provision requiring the newly established Bureau of Consumer Finance Protection (CFPB) to develop a combined form. The law requires a proposed disclosure be published with one year of the CFPB’s designated transfer date of July 21, 2011.

Late last month, the Treasury Department released a sample form that could potentially serve as a replacement to the existing TILA and RESPA disclosures. To view the sample form, click here.

The Treasury Department has been careful to note that the sample form is not being formally proposed by any federal agency and was developed in discussions between staff from the Federal Reserve and the Department of Housing and Urban Development (HUD) and that it serves only as a discussion draft and a consumer testing piece.

During MHI’s Annual Meeting held September 26-28 in Denver, Colorado, a special task force focused on analyzing and minimizing the impact implementation of the Dodd-Frank bill and formation of the CFPB will have on the manufactured housing industry was established.

Task force members and MHI staff are in the process of reviewing and prioritizing provisions impacting manufactured housing throughout the Dodd-Frank measure and will be meeting in mid-November to outline proposed legislative and regulatory remedies.

MHI members are encouraged to review the measure and submit their own recommended revisions. To view the legislation, click here.

MHI members can contact MHI Vice President of Government Affairs Jason Boehlert at 703-558-0660 or jboehlert@mfghome.org.

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