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…
The National Consumer Law Center submitted comments to the U.S. Department of Housing and Urban Development (HUD) regarding the lack of availability of small-dollar mortgages for consumers seeking funding to purchase or repair lower priced homes. The scarcity of these types of mortgages had a disparate impact on consumers of color who were forced to…
Read More about NCLC's Comments to HUD regarding Small Dollar Lending
Comments to the Housing and Urban Development Department re: 24 CFR Parts 203 and 206, [Docket No. FR-6151-P-02, RIN 2502-AJ51], 87 Fed. Reg. 63,458.
Read More about Comments to HUD Regarding Transitioning from LIBOR to Alternate Indices