The Massachusetts Association of Buyer Agents (MABA) plans to submit comments critiquing the Consumer Financial Protection Bureau’s (CFPB) "Know Before You Owe" proposals concerning mortgage disclosures, saying consumers simply don’t have enough time to comparison shop for mortgage offers given typical mortgage application process timelines.

The CFPB has been pushing a set of new rules intended to make it easier for consumers to compare offers from different lenders head-to-head. For, the agency requires lenders to provide an accounting of loan costs in the absence of points and other adjustments on the "good faith estimate" (GFE) given to consumers prior to a loan agreement being signed.

But, MABA says, by the time most consumers obtain GFEs, they’re so far along in the loan process they have little opportunity to approach other lenders.

Most lenders won’t issue a GFE until a buyer has made and offer on a particular property and signed a purchase and sale agreement.

"What winds up happening is, because the seller is always looking for the shortest time between [offer] and sale, there’s very little time for the consumer to shop," MABA Board President Sam Schneiderman, told Banker & Tradesman. In the Boston market, he said, most sellers typically allow buyers 30 to 45 days to obtain a mortgage, "and it typically takes 30 to 45 days to get a mortgage commitment" from a lender.

While the MABA board was supportive of the CFPB’s efforts to bring clarity to the mortgage marketplace and prevent the kind of abuses that contributed to the 2008 financial crisis, it also suggested the real problem is that many consumers don’t understand how loans are really structured. Thus, they often have a hard time making comparisons – something MABA said a good buyer’s agent can help with, of course.

"The bottom line: none of these rules will work unless there are timelines attached to them and penalties or incentives that will get the lenders to follow them," the board said in a statement.