Mortgage Market Share Report April 2011

?The four basis premises of writing: clarity, brevity, simplicity, and humanity.?

~ William Zinsser

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This week the Consumer Finance Protection Bureau released two samples of its proposed combination Good Faith Estimate (GFE) and Truth in Lending Disclosure (TIL). I must say that I?m surprised and impressed. Each of the two page samples are huge improvements over the present combination of a three page long GFE, a two page long TIL and a one or two page cash to close worksheet. I?ve included copies of each of the proposed forms (one from Ficus Bank and one from Pecan Bank) with this month?s report.??

The Pecan Bank disclosure is the one that I?d choose if it were up to me. Buyers typically want to know what their cash to close is, what their payment is and what their rate is. The Pecan disclosure gives them the cash to close number first. The payment information is right next to it. You?ve got to hunt for the rate a bit, but I wouldn?t characterize it as buried or hidden.??

I also like the way the actual costs of the loan over five years are clearly stated. This seems a much more meaningful and easy to comprehend number than the algorithm used to compute the APR.

I also like the CFPB?s tag line??Know Before You Owe.? I appreciate the subtle implication that the borrower has some responsibility to know what they?re signing up for.?

If you?d like to receive updates from the CFPB or comment on the form, you can sign up at the CFPB?s website. Here?s the url: http://www.consumerfinance.gov/You can comment on the form by following the link to the newsroom tab at the bottom of the page.

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~John Bethell