Bankers need to be especially alert to developing easily understood disclosures as they introduce more innovative and complex products that can be confusing to consumers. As you may know, the U.S. banking agencies recently issued proposed guidance on nontraditional mortgages.
The comment period for this interagency proposal closed on March 29, so we are now in the process of reviewing comments and determining how to proceed. Nontraditional mortgages allow borrowers to defer payment of principal and, sometimes, interest.