January 3, 2023 — Comments

We support the proposed rule but have a number of recommendations, including adding protections to protect distressed borrowers and prevent the misuse of escrow account refunds; removing repayment-plan payments from the definition of “monthly payment” used for the seasoning rule; and working with Congress to determine whether statutory changes are necessary to prevent other abuses of the IRRRL program.

National Consumer Law Center and Center for Responsible Lending

See all resources related to: