NAR Comments to CFPB on TILA or Fed Redux

This week, NAR submitted comments to the Consumer Financial Protection Bureau’s (CFPB) proposed rule amending Truth in Lending (Regulation Z) per Dodd-Frank. Much of this proposed rule looks familiar to you because CFPB is really just republishing regulations and proposed rules initially released by the Federal Reserve. In fact, the proposed rule states specifically that it does not “impose any new substantive obligations on persons subject to the existing Regulation Z, previously published by the Board.”

NAR’s comments were similar to those provided to the Federal Reserve in 2010. In the letter to CFPB, reiterated support to greater disclosure of appraisal fees, use of an expanded definition of value to include broker price opinions, and a definition for appraisal management companies (AMC) that goes beyond the number of appraisers on the AMC panel.