Joint trade letter on Know Before You Owe mortgage initiative
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These comments represent our thoughts on the CFPB’s memorandum dated February 21, 2012, entitled “Outline of Proposals Under Consideration and Alternatives Considered” (the Outline). We commend the CFPB for issuing this broad outline setting the regulatory context for the delivery of the reformed mortgage disclosures. It is important that all stakeholders work towards an improved mortgage disclosure system. In this sense, we believe that the objective of this reform process is not the mere issuance of a regulation. The real goal for all stakeholders is to ensure that we achieve a balanced and efficient set of rules to guide mortgage disclosures for the next generation. The true objective, as mandated by the Dodd-Frank Act, is to craft a solid and clear regulatory system that well accompanies a combination of two laws’ disclosures to so that they properly inform and protect consumers.