Some of the top mortgage lenders in the United States plan to move up their consumer disclosure- related processes even more than the CFPB is requiring under its integrated disclosure rule, which takes effect Aug. 1, 2015. It looks like they are just trying to be conservative and provide a bit of a cushion, at least in the initial transition period to a revamped disclosure regime. Bob Kelly, head of Truth in Lending Act/Real Estate Settlement Procedures Act implementation at Bank of America, told Inside the CFPB, “One thing that I think the CFPB sought to really have is that customers know before they owe. From a customer perspective, they often felt that the process to close was hurried and ...