October 16, 2012
CLTA Executive Vice President Craig Page recently sent written comments to the Consumer Financial Protection Bureau (CFPB) on its proposed rule relating to the definition and delineation of settlement fees and costs included in the “Total Finance Charge” and the related calculation of the Annual Percentage Rate (APR). In his letter, Page expressed the position of the CLTA that the proposed cancellation of the exemption of title insurance and closing fees from inclusion in finance charge and APR calculations is not warranted by a clear and significant benefit to consumers. In fact, the CLTA argued that the proposed rule could actually lead to consumer confusion.