On August 23, 2012, the Consumer Financial Protection Bureau (CFPB) published in the Federal Register (77 FR 51116) the following proposed rule: “Integrated Mortgage Disclosures under the Real Estate Settlement Procedures Act (Regulation X) and the Truth In Lending Act (Regulation Z)”. The proposed rule’s comment period ends on September 7, 2012, for proposed §§1026.1(c) and 1026.4. The proposed rule’s comment period ends on November 6, 2012, for all other proposed amendments to Regulation Z and Regulation X. This memo will address the proposed §§1026.1(c) and 1026.4, whose comment period ends September 7, 2012. Those clients wishing to comment must submit comments, and refer to Docket No.CFPB-2012-0028 or RIN 3170-AA19, by any of the following methods: 1. Electronic: http://www.regulations.gov. Follow the instructions for submitting comments. 2. Mail/Hand Delivery/Courier: Monica Jackson, Office of the Executive Secretary, Consumer Financial Protection Bureau, 1700 G Street, NW, Washington, DC 20552.

Complete Memorandum