The CFPB’s proposed changes to its TILA/RESPA Integrated Disclosure rule also would eliminate a degree of uncertainty by applying the rule’s existing disclosure requirements to cooperative units. Under the current rule, coverage of cooperative units depends on whether cooperatives are classified as real property under state law. Because state law sometimes treats cooperatives differently for different purposes, there may be uncertainty and inconsistency among market actors.As a result, the CFPB is proposing to require the provision of the integrated disclosures in transactions involving cooperative units, whether or not such units are classified under state law as real property. This would apply to closed-end credit transactions, other than reverse mortgages. “In at least some states, ownership of a share in ...