November 6th was not only Election Day but also the deadline to submit public comments to the CFPB on the remaining proposed mortgage financing rule related to the Integrated Combined RESPA/TILA Disclosure. TMHA once again, as we have done for all the previous federally proposed rules, submitted our comments on the proposed rule.
Recall this proposed federal rule already contained a major victory for our industry with the exclusion for “home-only” or chattel lending. In our comments we sought to fortify this proposed exclusion as well as address additional problematic elements of the rule related to land-home transactions, increased liability provisions, and the “all in financing charge” proposal that would have an impact extending beyond the RESPA/TILA Rule.
Also, in our next Texas MH Quarterly magazine, which went to press on November 7, there is a detailed article about the progress and process of all the pending mortgage related federally proposed rules. Stay tuned.