Comments to VA Regarding Proposed Revisions to the VA-Guaranteed or Insured Interest Rate Reduction Refinancing Loans Program
NCLC and CRL 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…