ARLINGTON, Va.– NAFCU sent a comment letter to the Federal Reserve regarding its proposed amendments to Regulation Z to prohibit certain unfair, abusive or deceptive practices in connection with closed-end mortgage loans.
The proposed rule would create seven new protections or restrictions for mortgage lending, specifically for higher priced mortgage loans and others applying to all mortgage loans secured by a principal dwelling; modify the disclosure requirements for mortgage advertisements; and revise the timing requirements for providing disclosures for closed-end mortgages.
NAFCU said it was generally supportive of the rule but expressed some concern about the increased regulatory burden it imposes. "NAFCU believes it is imperative that the definition of a 'higher-priced mortgage loan' be narrowly tailored to the subprime market in order to avoid any adverse impact on the cost and availability of credit in the prime or near-prime markets," wrote, B. Dan Berger, senior vice president of government affairs for NAFCU.
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