Comment on CFPB-2013-0009-0001

This message is intended to convey to the Bureau 1. the present and anticipated impact on our credit union and our members and borrowers of the rule on High Priced Mortgage Loans (1026.35 including the amendment effective 01 June 2013); and, 2. the present effect of Bureau rules regarding Multi-feature Open End Lending (MFOEL) in Regulation Z as applied by our prudential regulator when it “consulted with the… Bureau” on this matter (1026.2(a)(20) and NCUA Letters to FCUs 10-FCU-02 and 12-FCU-02). The actions and the Regulation Z rules of the Bureau, both generally as to Open End Lending, and also specifically as to 1026.35, will effectively gut approximately $1/3 million dollars of consumer mobile home lending at our institution over the next three year period denying access to our lending for about 10 consumer borrowers that would otherwise benefit. Seemingly insignificant in the national scope, yet for the consumers of our County and for our small lending institution, this is significant. Our credit union charter is for service to a rural district and designated by NCUA as serving a low-income field of membership. Yet, on a technicality, we do not qualify for the June-effective rule ‘small creditor’ exemption that would otherwise permit our continued lending to this underserved mobile home market. The narrow application by the Bureau of the term ‘rural’ fails to recognize the wisdom of Congressional delegation to NCUA of “the authority to define by regulation the meaning of a … rural district for Federal credit union charters”. [75FR 36258ff] Consequently, the Bureau not only damages the service of our credit union to our members, but disadvantages the consumers of our rural Douglas County, Oregon. Finally, we also question the application made by the Bureau of ‘underserved’ and apparently failing to use or consider alternatives of other agencies such as CDFI and NCUA.