January 3, 2023 — Comments

We support the proposed rule but have a number of recommendations, including adding protections to protect distressed borrowers and prevent the misuse of escrow account refunds; removing repayment-plan payments from the definition of “monthly payment” used for the seasoning rule; and working with Congress to determine whether statutory changes are necessary to prevent other abuses of the IRRRL program.

National Consumer Law Center and Center for Responsible Lending