The Mortgage Bankers Association (MBA) has filed two comment letters with the Board of Governors of the Federal Reserve System, both relating to the proposed amendments to Regulation Z, the implementing regulation for the Truth-in-Lending Act (TILA). The first letter specifically addresses the proposed rules to revise consumer disclosures and compensation practices for closed-end credit transactions--a credit agreement in which the amount advanced, plus any finance charges, is expected to be repaid in full by a specified date, such as your traditional 30-year fixed mortgage.
The second letter addresses the proposed rules on open-end credit transactions--credit agreements allowing a customer to borrow against a preapproved credit line when purchasing goods and services, an example fo which could be a home equity line of credit (HELOC).
In both letters, MBA expresses concern that the proposed rules could harm consumers and increase costs unnecessarily. The letters suggest improvements to the proposed rules (and the disclosures) that would avoid potential unintended consequences.
To read the MBA comment letter on closed-end transactions, click here.
To read the MBA comment letter on open-end transactions, click here.
For more information, visit www.mortgagebankers.org.