The FTC submitted a comment in response to the CFPB's notice of proposed rulemaking requesting comments to its proposal to combine certain disclosures consumers receive in connection with applying for and closing on a home mortgage loan under TILA and RESPA (see July 10, 2012 Alert). The FTC's comment commended the CFPB's efforts and stated that the disclosures likely will improve the information that consumers receive. The comment suggests that the CFPB conduct controlled quantitative testing before finalizing the rule to ensure that key mortgage terms are not misinterpreted or misunderstood. In its press release announcing the comment, the FTC noted that in its own 2007 study, it found that mortgage terms and costs were not adequately conveyed to consumers.
Goodwin Procter LLP is one of the nation's leading law firms, with a team of 700 attorneys and offices in Boston, Los Angeles, New York, San Diego, San Francisco and Washington, D.C. The firm combines in-depth legal knowledge with practical business experience to deliver innovative solutions to complex legal problems. We provide litigation, corporate law and real estate services to clients ranging from start-up companies to Fortune 500 multinationals, with a focus on matters involving private equity, technology companies, real estate capital markets, financial services, intellectual property and products liability.
This article, which may be considered advertising under the ethical rules of certain jurisdictions, is provided with the understanding that it does not constitute the rendering of legal advice or other professional advice by Goodwin Procter LLP or its attorneys. © 2012 Goodwin Procter LLP. All rights reserved.
