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August 3, 2009 - On July 30, NASCUS filed a comment letter in response to Federal Trade Commission (FTC) Advanced Notice of Proposed Rulemaking (ANPR) on mortgage acts and practices. The Omnibus Appropriations Act of 2009, signed into law in March, directed the FTC to initiate a rulemaking proceeding with respect to mortgage loans.
FTC commenced with rulemaking addressing practices with regard to mortgage loan advertising and marketing, origination, appraisals and servicing. Given its broad discretion, FTC chose to extend its rulemaking to cover are those over which the FTC has jurisdiction under the FTC Act – which includes state-chartered credit unions, but excludes banks, thrifts and federal credit unions.
NASCUS’ comment letter, while supportive of FTC’s goal of consumer protection, urges FTC to exempt state-chartered credit unions on the grounds that state-chartered credit unions 1) are highly regulated entities that already comply with Regulation Z; and 2) would suffer a disparate impact in the market place with little offsetting benefit to consumers if only state-charters are subject to this rule. In addition, subjecting state-charters to this rule exclusively among depository institutions could 3) confuse consumers, and 4) credit union members are uniquely empowered to vindicate their rights through the board election process.
To view NASCUS’ comment letter, follow this link.
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