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On July 9, the CFPB issued a Request for Information seeking public input on potential changes to mortgage disclosure and rescission requirements under the Truth in Lending Act and the Real Estate Settlement Procedures Act. The CFPB is considering whether revisions to the TRID Rule, the right of rescission, and reverse mortgage disclosures could reduce regulatory burdens and expand access to mortgage credit. Comments are due August 10, 2026.
The RFI implements portions of a March 2026 executive order (previously discussed here) directing the CFPB to consider changes to federal mortgage rules, particularly those affecting smaller banks. The CFPB is requesting data on whether existing requirements increase costs, delay closings, or otherwise affect credit availability. Specifically, the RFI seeks comment on:
- TRID timing requirements. The CFPB asks whether the waiting periods for Loan Estimates and Closing Disclosures should be modified, supplemented, or replaced with a materiality-based standard that could reduce closing delays while preserving consumer clarity.
- Disclosure tolerances and revisions. The Bureau seeks input on whether existing zero and 10 percent tolerance thresholds should be adjusted and whether additional guidance could reduce the need for revised disclosures following changed circumstances.
- Rescission rights. The CFPB asks whether the three-business-day post-consummation rescission period, when combined with the pre-consummation TRID waiting period, unnecessarily delays funding for refinance transactions.
- Requirements for smaller institutions. The RFI requests feedback on whether small banks and credit unions should receive exemptions, alternative requirements, or other tailored treatment under the TRID Rule.
- Reverse mortgage disclosures. The CFPB is considering integrated forms designed specifically for reverse mortgages, changes to the total annual loan cost table, and disclosures illustrating how loan balances increase over time.
Putting It Into Practice: The RFI is the CFPB’s first concrete step toward implementing the mortgage regulatory changes directed by the March executive order. Although the RFI does not change current obligations, it may lead to significant revisions to RESPA and TILA requirements. Mortgage market participants should monitor the rulemaking process and prepare to update disclosure systems and closing procedures as necessary.
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