CFPB Issues RFI Aiming to Reduce Regulatory Burdens of and Promote Access to Mortgage Credit

The CFPB issued a Request for Information (RFI) seeking public comment on issues related to TILA-RESPA integrated disclosures (TRID), reverse mortgage disclosures, and rescission rights.  The RFI was issued consistent with Executive Order 14393, which addresses amending TRID rules, among other things, and with the CFPB’s express objective to reduce unwarranted regulatory burdens.

The RFI includes twenty-two questions that are split into four sections:

• TRID and right of rescission timing requirements – These questions focus on how to decrease process cost and mortgage credit access barriers caused by TRID and right of rescission timing requirements. The section includes requests for comments on changing the timing or standards for delivery of the LE and CD, on reducing the incidence of revised disclosures, and on adjusting waiting periods for TRID and right of rescission.
• Other TRID requirements – This section requests comments on, among other things, modifying TRID disclosure forms, the CFPB providing additional guidance on acceptance of electronic forms and signatures, the CFPB providing additional guidance on changed circumstances, and changes to or clarifications of construction loan requirements.
• Tailored requirements for small banks and credit unions – These two questions ask if any changes to the TRID rule should be considered for small banks and credit unions due to possibly unique aspects of these entities, and whether such changes would lower costs for any mortgage participants.
• Reverse mortgages – This section notes CFPB’s awareness of the difficulties reverse mortgage companies have applying TILA and RESPA, and asks questions about integrating and tailoring those disclosures, changing the total annual loan cost table for better accuracy and consumer understanding, and tailoring informational disclosures.

Comments are due by August 10, 2026.