Comments to the Federal Reserve System re: Supplemental comments on Docket No. R-1775 and RIN 7100-AG34 submitted by the Structured Finance Association and the National Consumer Law Center (on behalf of our low-income clients).
As explained during our September 8, 2022 meeting with Board staff members, the National Consumer Law Center and Structured Finance Association recommend making the following changes to the proposed rule. These changes will provide needed clarity to all parties in the residential mortgage and student loan markets.