The data collected will be used to
inform CFPB's design and development of the mandated integrated
disclosure and its implementation. The information collected
through the one-on-one cognitive interviews will inform the design,
using an iterative process to improve the disclosure so that the
final disclosure is one that consumers can use to identify the
terms of the loan being offered to them and use that information to
compare among different loan offers.
The Department of the
Treasury (Treasury), on behalf of itself and the Consumer Financial
Protection Bureau (CFPB), respectfully requests emergency
processing and approval of the collection of information to be used
for the qualitative testing of integrated mortgage loan disclosure
forms. The collection is needed prior to the expiration of the time
periods set out in 5 C.F.R. Part 1320. The Dodd-Frank Wall Street
Reform and Consumer Protection Act, Public Law No. 111-203, Title X
(the Dodd-Frank Act) requires CFPB to propose rules and model
disclosures that combine the disclosures required under the Truth
in Lending Act and sections 4 (the HUD-1) and 5 (the GFE) of the
Real Estate Settlement Procedures Act, into a single, integrated
disclosure for mortgage loan transactions covered by those laws.
(Dodd-Frank Act § 1032(f)). The Dodd-Frank Act mandates that a
proposed rule be issued within one year after the Transfer Date,
which is July 21, 2011. The target date is to issue the proposed
rule as soon after the Transfer Date as possible. Section 1032 of
the Dodd-Frank Act provides that any model form issued pursuant to
this subsection shall be validated through consumer testing. To
effectively test the model form, the CFPB implementation team has
determined that both qualitative and quantitative testing of the
form will be necessary. It has further determined that the
qualitative evaluation of the form, as part of the iterative
process of the design, needs to be initiated in May 2011, to allow
five months for revisions and re-testing. Beginning in September,
the CFPB implementation team will undertake a quantitative study to
validate the form (an ICR for that data collection will be
submitted separately). The aggressive schedule is necessary to have
a validated disclosure form in January 2012, so that proposed
regulations can be drafted and published by July 21, 2012, as
mandated in the Dodd-Frank Act. The CFPB implementation team
recognizes the importance of this disclosure to improving the
market for mortgage loans and wants to move forward as quickly as
possible with a regulation to implement a disclosure that
successfully communicates information to consumers about the terms
of loans and enables consumers to be able to understand and compare
the loan products being offered. Given the timing of the consumer
testing, the CFPB implementation team cannot reasonably comply with
the normal clearance procedures under 5 C.F.R. Part 1320 with
respect to this information collection.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
OMB Memo on Round 5 draft v4.docx
Background Narrative - 4th Round Testing.pdf
Memo to OMB on changes.doc
Outreach