On July 22 TMHA submitted another comment letter to the CFPB regarding federal rules proposing to amend certain mortgage rules issued by the CFPB in January 2013. The proposed amendments focus primarily on loss mitigation procedures under Regulation X's servicing provisions, like the amounts counted as loan originator compensation to retailers and their employees for purposes of applying points and fees thresholds under HOEPA, and the qualified mortgage rules in Regulation Z, which include exemptions available to creditors that operate predominantly in “rural or underserved,” application of the loan originator compensation rules to bank tellers and similar staff, and the prohibition on creditor-financed credit insurance.
The CFPB also proposed to adjust the effective dates for certain provisions of the loan originator compensation rules to align with the calendar year of January 1, 2014.
A total of 272 comment letters where submitted on these proposed rules. For the manufactured housing industry in addition to TMHA’s comment letter, MHI, 21st Mortgage, CAVCO Homes and Vanderbilt Mortgage also sent in comments.