October 29, 2014
I have submitted a Comment on Home Mortgage Disclosure Act Proposed Rulemaking to the Consumer Financial Protection Bureau. Basically, I argue
The Consumer Financial Protection Bureau’s Home Mortgage Disclosure Act proposed rulemaking (proposed Aug. 29, 2014) is a reasonable one. It increases the amount of information that is to be collected about important consumer products, such as reverse mortgages. It also increases the amount of important information it collects about all mortgages. At the same time, it releases lenders from having to determine borrowers’ intentions about how they will use their loan proceeds, something that can be hard to do and to document well. Finally, while the proposed rule raises some privacy concerns, the CFPB can address them.