Testimony, Comments, Correspondence
NCSHA Comments to CFPB on Concurrent Rule Exempting HFAS from Ability-to-Repay/QM Rule
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 Bureauās (CFPB) January 10 proposed rule amending the Ability-to-Repay standards under the Truth in Lending Act.
NCSHA Comments to CFPB on Integrated TILA/RESPA Disclosure Forms
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 Bureauās (CFPB) July 9 proposed rule integrating the disclosures required under the Real Estate Settlement Procedures Act (RESPA) and the Truth in Lending Act (TILA).Ā
NCSHA Comments on CFPB Lender Compensation Rule
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:Ā 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 Comments to CFPB on RESPA Mortgage Servicing Rule
NCSHA supports CFPBās 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 Comments to CFPB on TILA Mortgage Servicing Rule
NCSHA supports CFPBās efforts to increase consumersā 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 Comments to CFPB High-Cost Mortgage Rule
NCSHA shares CFPBās 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.
