July 19, 2011
The CLTA commented on July 6th to the Bureau of Consumer Financial Protection (BCFP) on its most recent draft mortgage disclosure form. The CLTA expressed the view that charges should only be included in the form if usually incurred by the buyer/borrower. The proposal includes charges which are often not actually a cost of the borrower. The CLTA letter explained in detail how buyer/borrower payment practices vary geographically in California based on custom and practice and gave examples of escrow fees, transfer taxes and title insurance cost.