• Improve the disclosure of the annual percentage rate (APR) so it captures most fees and settlement costs;
• Require lenders to show how the consumer's APR compares to the average rate offered to borrowers with excellent credit;
• Require lenders to provide final Truth in Lending Act disclosures at least three business days before loan closing; and
• Require lenders to show consumers how much their monthly payments might increase, for adjustable-rate mortgages.

There's lots more to the Fed's offering, including rules making it harder for mortgage brokers to steer consumers to bad loans, and simpler and more timely disclosure of HELOC terms.

All of that is a good start toward preventing the outrages that led millions of homeowners over the precipice in recent years. But one has to ask: Why were these better disclosures proposed now? Why not years ago? More to the point, is disclosure, the theme of many of these proposed changes, really the best type of consumer protection?–Tobie Stanger