On March 28, the Consumer Financial Protection Bureau (CFPB) filed a notice in the Federal Register requesting public comment regarding the quantitative testing of the integrated mortgage loan disclosure forms.

Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, the CFPB is required to develop mortgage disclosure forms that merge the current RESPA and Truth in Lending Act (TILA) disclosures. Dodd-Frank mandates that the CFPB must publish proposed forms by July 21.

“The bureau proposes to conduct quantitative testing of the integrated disclosures after it publishes the proposed integrated disclosures,” the CFPB wrote in the notice. “The purpose of the quantitative testing will be to examine whether the disclosures aid consumers in understanding the terms of the mortgage loan that is the subject of the disclosure.”

The CFPB said it plans to contract with a consumer research firm to formulate a testing plan, conduct the testing and provide a report summarizing the results. 

“The results will assist the bureau in determining the efficacy of the proposed integrated disclosures, in furtherance of the statutory purpose of the integrated disclosures under TILA and RESPA, which is, in part, to aid the consumer in understanding the transaction,” the bureau wrote.

The CFPB invites comments on:

• Whether the collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility;
• The accuracy of the agency’s estimate of the burden of the collection of information, including the validity of the methodology and the assumptions used;
• Ways to enhance the quality, and clarity of the information to be collected; and
• Ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques or other forms of information technology costs and costs of operation, maintenance and purchase of services to provide information.

Comment must be received by May 29.