Comments to the Notice of Assessment of 2013 RESPA Servicing Rule and Request for Public Comment
NCLC and other consumer advocacy groups issued a comment to the CFPB regarding the 5-year assessment of its mortgage servicing rules.
The consumer groups confines our comments to six topics: § 700.3(c) FTC should clarify that the Act applies to consumer leases § 700.10(b) Certain 50/50 warranties should be interpreted as violating the Act’s anti-tying provision § 700.11(a) FTC interpretation of Act’s application to insurance contracts conflicts with a federal statute and Supreme Court precedent §…
The undersigned sixteen organizations, representing California borrowers, educators, and consumer advocates, submit this comment in response to the California Department of Financial Protection & Innovation’s (“DFPI” or “Department”) notice of proposed rulemaking to adopt new regulations and amend current regulations implementing the Student Loan Servicing Act (SLSA), Fin. Code, § 28100, et seq., and to…