CUNA wants consumer advisory language strengthened in the proposed guidance regarding reverse mortgages while NAFCU would like to see additional guidance on what information must be included in advertisements.

The associations' comments came in recent letters to the Financial Institutions Advisory Council, which sent the proposed guidance out for comment in December.

CUNA Senior Assistant General Counsel Jeffrey Bloch wrote that the mandatory consumer counseling before a reverse mortgage can be approved should have to take place in person, rather than by telephone. He also recommended that while consumers should receive "general guidance and information," before they apply, the counseling sessions should take place after they file the application.

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