CFPB should also maintain the flexibility in the issuance of the loan estimate instead of requiring it when only six pieces of information are collected. The practical effect of this is that information essential to properly evaluating a loan prospect will either not be collected and/or estimated closing costs will be outlandishly high in order to avoid tolerance infractions. The result could very well be that lenders with the least expensive ultimate closing costs will not appear that way to consumers because their loan estimates appear more costly. This would not ultimately benefit consumers.
There are numerous other proposed changes that could be adopted or scrapped. NAR believes most should be scrapped and CFPB should focus on simply improving the loan estimate that ensures it provides consumers with timely and accurate information. In terms of implementing new regulations, 2014 will already be a costly and confusing year. There is no need to make it even worse by piling on massive changes to the closing process, some of which were unworkable as originally proposed.
This column is brought to you by the NAR Real Estate Services group. Ken Trepeta is the director of Real Estate Services for the National Association of REALTORS®.
