Comment on CFPB-2013-0002-0001

Document ID: CFPB-2013-0002-0202
Document Type: Public Submission
Agency: Consumer Financial Protection Bureau
Received Date: February 22 2013, at 12:00 AM Eastern Standard Time
Date Posted: February 25 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: January 30 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: February 25 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-83tx-xd14
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This is comment on Proposed Rule

Ability to Repay Standards under Truth in Lending Act (Regulation Z)

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In higher cost states the 3% cap on points and fees will disqualify borrowers based on loan higher loan amounts. Lenders, title and escrow, closing attorneys will not and in some cases by law can not reduce their fees. The cap should only apply to fees charges to originate including processing, doc fee etc. but not title and escrow fees. This could quite possibly put a complete halt to real estate lending.

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Comment on CFPB-2013-0002-0001
Public Submission Posted: 02/25/2013 ID: CFPB-2013-0002-0266