Testimony, Comments, Correspondence
On behalf of the state Housing Finance Agencies (HFAs) it represents, the National Council of State Housing Agencies (NCSHA) appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) July 9 proposed rule integrating the disclosures required under the Real Estate Settlement Procedures Act (RESPA) and the Truth in Lending Act (TILA).
October 16, 2012 Mr. Richard Cordray, Director C/O Monica Jackson, Office of the Executive Secretary Bureau of Consumer Financial Protection 1700 G Street, NW Washington, DC 20552 Re: CFPB-2012-0037 Dear Director Cordray, On behalf of the state Housing Finance Agencies (HFAs) it represents, the National Council of State Housing Agencies (NCSHA) welcomes the opportunity to
NCSHA supports CFPB’s efforts to increase consumer protection in the mortgage servicing industry. However, we feel that some of the provisions of the proposed rule will be overly costly to smaller servicers, including government agencies such as HFAs. Consequently, we ask you to eliminate the provision that would require servicers to respond to requests for information or error resolution requests that are received orally, and instead only require servicers to respond to such requests when they are submitted in writing.
NCSHA supports CFPB’s efforts to increase consumers’ access to comprehensive and timely information about their home loans. However, we believe that the Bureau should also avoid imposing requirements that will overly burden small servicers with fewer resources. This includes not only small private servicers, but also instrumentalities of government (IOGs), including HFAs.
NCSHA shares CFPB’s goals of discouraging inappropriate lending practices and providing robust protections for borrowers who take out high-cost mortgages. However, we believe federal regulations must also ensure that responsible loans are not classified as high-cost. Consequently, we urge you to exempt HFA-financed loans from the application of the high-cost mortgage rule.
Thank you for the opportunity to comment on HUD’s proposed rule to make conforming changes to the regulations of the Section 8 Tenant-Based Voucher and Section 8 Project-Based Voucher (PBV) programs to reflect the self-executing provisions of the Housing and Economic Recovery Act of 2008 (HERA), to amend the regulations required to implement those statutory provisions of HERA that are not self-implementing, and to make other changes to update or clarify regulations.