Phillip Matous, president/CEO of the $53 million Total CommunityCredit Union of Taylor, Mich. has thrown the book – a heavy one –back at his legislators and regulators.

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To emphasize how the compliance burden on credit unions hasreached a “ridiculous” point, Matous printed copies of the1,099-page Consumer Financial Protection Bureau request for commenton its proposed combined mortgage disclosure rules and mailed them with hiscomment letter to U.S. Reps. John Dingell (D-Mich.) and Gary Peters (D-Mich.), U.S. Sens. Debbie Stabenow (D-Mich.) and Carl Levin (D-Mich.), CFPB Director Richard Cordray and NCUA Chairman Debbie Matz.

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Printed double-sided, Matous said the request for comment ismore than 2 inches thick.

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“I hope that by seeing the ponderous size of the enclosed CFPB1,099-page proposed rule concerning RESPA and Truth in Lending, youcan appreciate the damage current regulations are having on ourdemocracy and republic,” Matous wrote in his comment letter, whichhe also emailed to colleagues and the media.

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“This is rule by edict under the guise of democracy. If theregulations overwhelm the regulated,” Matous wrote, “the regulatorcan easily impose their will on the public. Who can easily digestand comment on such voluminous writing?”

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Chair of the Michigan Credit Union League Legislative Issuesworking group, Matous said he enjoys reading new regulations, buthe criticized a recently released interagency 211-page rule that places new restrictions on higher-riskmortgages.

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He sourced one paragraph in the rule that cited several crossreferences, which he said requires nearly 18 years of education tounderstand, according to the Flesch-Kincaid Grade LevelFormula.

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That complexity violates the Plain Writing Act of 2010,according to the CEO of the 7,100-member suburban Detroit creditunion, and he urged the CFPB and other regulators to comply withthe law, as well as an executive order from President Obamamandating the same.

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“Such voluminous requests for comments are becoming the norm,”Matous wrote. “They are harming, not aiding consumers, and ourdemocracy. Regulators will not receive the benefit of years offield experience that could enhance the benefits in theirproposals.”

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