The Clearing House Association filed a comment letter in response to the CFPB’s NPR on integrating mortgage disclosures under RESPA and TILA. The letter states that an “all-in” finance charge is inappropriate at this time without further study of its interaction with other mortgage laws, such as HOEPA, and supports the proposed delay in the implementation of certain disclosure requirements established by Title XIV of Dodd-Frank. The letter also recommends that the CFPB carefully consider the interplay and sequencing of this proposal with other pending rulemakings and publish its expected rulemaking schedule for comment. TCH will be following up with the CFPB after the recently-extended comment period ends.