Continuing with its work on a combined TILA/RESPA application disclosure, the Bureau has posted yet another round of model disclosure forms for comment by consumers and the industry, this time focusing on the differences between fixed and adjustable rate loans. The fixed rate form (Pinyon Bank) is fairly straightforward. The adjustable rate form (Yucca Bank) includes additional information, including projected payment calculations in subsequent years of the loan, as well as an Adjustable Interest Rate (AIR) table that highlights the terms of the adjustable rate feature. The Bureau has also indicated that it is currently testing a new disclosure prototype design in New Mexico.
The Bureau has indicated that it has turned its attention to disclosures to be provided at loan closing and has begun working on a disclosure form that informs borrowers of final loan terms and costs. It intends to post a prototype loan closing disclosure for comment in the near future, noting that the application and closing disclosures must be both clear and effective and must work together to further borrowers’ understanding of their loans.