AFR joined public interest groups in weighing in on the CFPB’s proposal defining larger market participants for student loan servicing.
AFR joined public interest groups in weighing in on the CFPB’s proposal defining larger market participants for student loan servicing.
AFR joined public interest groups in submitting a comment letter to the CFPB, arguing that additional information regarding private student loan servicing and collection is needed to design an effective loan modification program.
AFR submitted a comment letter to the CFPB calling for yield spread premiums to be included in the calculation of points-and-fees thresholds. This inclusion is very important to carrying out the Dodd-Frank Act directive that prohibits steering borrowers to more expensive loans.
AFR submitted a comment letter to the CFPB arguing for the need of rigorous consumer protections attached to any corporate field testing of new disclosure forms.
In an Oct. 9th letter to the CFPB, AFR criticized the bureau’s proposed rule for mortgage servicers, especially a provision allowing servicers to take a “dual-track” approach – considering a loan modification and pursuing foreclosure at the same time. The letter, co-signed by the NAACP, the Consumer Federation of America, Consumers Union, the AFL-CIO, and […]
AFR joined more than 35 organizations in signing onto a comment letter regarding the CFPB’s servicing standards proposal.
AFR submitted a comment letter to the CFPB regarding their servicing standards proposal.
AFR submitted a comment letter to the CFPB on their proposed rules implementing Dodd-Frank changes regarding high cost mortgage loans. The letter argues against changing triggers for high cost loans for smaller loans which the statute allows but does not require, and argues that the proposal should be strengthened in various ways, including by making sure that borrowers in revolving lines of credit get the same protections as those in closed end mortgages.
AFR submitted a comment letter cosigned by more than two dozen other organizations urging them to ensure that prepaid cards will be safe, fair, and appropriate for the consumers that use them.