CFPB Approves Application for Alternative Construction Disclosures

The CFPB recently announced it has approved an application from the Independent Community Bankers of America (ICBA) to test alternative disclosures for construction loans, and more specifically, for single-close, construction-to-permanent loans.

The ICBA had applied to the CFPB for the ability to make some changes to how the Loan Estimate and Closing Disclosure look today for these types of loans. Its goal was to increase the availability of these loans and a borrower’s understanding of them. The CFPB’s approval allows for “real-world” testing of these disclosures by approved lenders. Lenders interested in being part of this testing need to first apply to the CFPB for permission. Additional details on what information is necessary to get this ball rolling for interested institutions are provided in the both CFPB’s announcement and in the Trial Disclosure Program Waiver Template.

Regardless of where this goes, this is a pretty good indication that the CFPB is interested in making some changes to construction loan disclosures. While this testing process could take some time, we hope it will lead to changes for better understanding…both for borrowers and financial institutions. Stay tuned!

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Published
2023/11/30

Amy Kudlacek

Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!

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