CFPB Opens Public Comment Period On Sweeping Mortgage Disclosure And Rescission Rule Changes

The Consumer Financial Protection Bureau issued a Request for Information on July 9, seeking public input on potential changes to mortgage disclosure and rescission requirements.

The RFI targets rules under the Truth in Lending Act and the Real Estate Settlement Procedures Act, two of the most significant federal frameworks governing mortgage lending.

The CFPB is considering whether revisions to the TRID Rule, the right of rescission, and reverse mortgage disclosures could reduce regulatory burdens and expand access to mortgage credit.

The move implements portions of a March 2026 executive order that directed the CFPB to consider changes to federal mortgage rules, particularly those affecting smaller banks.

The bureau is requesting data on whether existing requirements increase costs, delay closings, or otherwise affect credit availability across the mortgage market.

On timing requirements, the CFPB is asking whether waiting periods for Loan Estimates and Closing Disclosures should be modified or replaced with a materiality-based standard to reduce closing delays.

The RFI also seeks input on whether existing zero and 10 percent tolerance thresholds should be adjusted, and whether additional guidance could reduce the need for revised disclosures following changed circumstances.

The CFPB is questioning whether the three-business-day post-consummation rescission period, combined with the pre-consummation TRID waiting period, unnecessarily delays funding for refinance transactions.

Smaller institutions are also addressed in the RFI, with the bureau requesting feedback on whether small banks and credit unions should receive exemptions or alternative treatment under the TRID Rule.

On reverse mortgages, the CFPB is considering integrated forms designed specifically for those products, changes to the total annual loan cost table, and disclosures illustrating how loan balances increase over time.

The RFI represents the CFPB’s first concrete step toward implementing the mortgage regulatory changes directed by the March executive order, making it a significant moment for the sector.

Although the RFI does not change current obligations, it may lead to significant revisions to RESPA and TILA requirements that would affect lenders across the country.

Mortgage market participants should monitor the rulemaking process and prepare to update disclosure systems and closing procedures as necessary ahead of any formal rule changes.

Comments on the RFI are due by August 10, 2026, giving industry participants and consumer groups a narrow window to shape the direction of potential reforms.