On July 9, the Consumer Financial Protection Bureau (CFPB) published a request for information (RFI) seeking public comment on proposed changes to the mortgage origination framework to improve credit availability and reduce compliance burdens for financial institutions.
The RFI was issued pursuant to Executive Order 14393, “Promoting Access to Mortgage Credit” (March 13, 2026), which states that recent statutory and regulatory changes have limited access to credit for certain creditworthy borrowers. The EO directs the CFPB to consider a series of mortgage-related regulatory and supervisory changes to “improve the availability and affordability of mortgage credit, tailor rules for community banks and “smaller banks” [and] reduce the regulatory burden on community banks.” Specifically, the EO requests that the CFPB consider:
- Proposing amendments to Regulation Z to tailor ability to repay (ATR)/qualified mortgage (QM) requirements.
- Replacing TRID timing rules with a materiality-based standard that “preserves consumer clarity and reduces closing delays.”
- Exempting rate-and-term refinancing (including cash-out refinancing) from rescission rights.
Request for comment
Consistent with the EO’s directive – and the CFPB’s objective to identify and address “outdated, unnecessary, or unduly burdensome regulations” – the RFI specifically solicits input on the Truth in Lending Act-Real Estate Settlement Procedures Act (TILA-RESPA) Integrated Disclosure (TRID) rule, the right of rescission under TILA for certain refinance transactions, and disclosure requirements for reverse mortgages.
TRID timing requirements
A central focus of the RFI is the TRID framework. The CFPB notes that TRID’s timing requirements and tolerance thresholds may introduce operational complexity and delay loan closings, and seeks comment on how these requirements could be reformed.
Among other issues, the CFPB asks whether:
- The three-business-day requirement to deliver the loan estimate after application, the seven-business-day waiting period between loan estimate delivery and consummation, and the requirement that consumers receive the closing disclosure no later than three business days before consummation affect borrowers’ ability to access credit and/or increase costs for lenders and consumers.
- Existing rules requiring revised disclosures upon “changed circumstances” impose undue burdens, particularly if creditors must issue updated disclosures within three business days of receiving information that triggers a revision.
- A materiality-based approach could replace or supplement current timing rules, preserving consumer clarity while reducing administrative delays.
- Disclosures could be provided earlier in the origination process, and whether the TRID forms themselves could be revised to improve consumer comprehension and loan execution.
- Additional guidance on the acceptability of electronic and digital forms and signatures would promote their use and reduce costs for consumers.
Other TRID requirements
Tolerance thresholds. The RFI raises questions about the TRID tolerance framework, including the distinction between zero tolerance, 10% tolerance and unlimited tolerance categories. The CFPB seeks comment on whether changes to the tolerance thresholds could improve loan execution and access to credit, and lower costs for consumers.
Changed circumstances. The CFPB is also considering whether clearer guidance on “changed circumstances” could help reduce the frequency of required revised disclosures while maintaining accurate cost estimates for consumers.
Construction loans. The CFPB seeks comment on whether to amend or clarify requirements specific to construction loans, including whether certain requirements should be waived.
Secondary market implications. The CFPB questions how potential TRID changes would impact the pricing, liquidity or demand for mortgages, mortgage-backed securities, mortgage servicing rights and other mortgage-backed capital markets instruments.
Right of rescission
The CFPB is also evaluating whether the current right of rescission framework, which provides a post-consummation rescission period for certain transactions, remains justified in light of TRID’s pre-consummation disclosure requirements.
Currently, under TILA and Regulation Z, the rescission period begins after the last of three events: consummation of the transaction; delivery of all material disclosures; and delivery to the consumer of the required rescission notice. In practice, for borrowers who have not waived their rescission right for a bona fide personal financial emergency, the three-day post-consummation rescission waiting period – coupled with the three-day pre-consummation TRID waiting period – means consumers in rescindable transactions have approximately one week to review the loan’s final terms. The CFPB asks whether this structure unduly delays loan funding – particularly in refinance transactions – and whether adjustments could streamline the process without undermining consumer protections.
Tailored requirements for small banks and credit unions
The CFPB asks for comment on implementing changes to the TRID rule as it relates to small banks and credit unions and whether revisions are structured as exemptions or alternative requirements. The CFPB also asks whether changes exclusive to small banks and credit unions would lower costs for both creditors and consumers alike.
Reverse mortgage disclosures
The CFPB is examining the current disclosure regime for reverse mortgages. Because reverse mortgages are excluded from TRID and are instead subject to overlapping TILA and RESPA requirements – including the good faith estimate and HUD-1 forms that are not tailored for reverse mortgage transactions – the CFPB is considering a more integrated, tailored disclosure framework to better serve consumers and minimize confusion.
Looking ahead
While the RFI does not propose specific rule changes, it signals an openness to revisiting long-standing requirements governing mortgage origination.
Comments must be received by August 10, 2026. Stakeholders across the mortgage industry –including lenders, servicers, community banks, investors, secondary market participants and consumer advocates – may consider engaging in the comment process, particularly given the potential scope of changes to TRID compliance, disclosure timing, rescission practices, construction loan requirements and other regular practices that will affect their operations.