Comment on CFPB-2013-0013-0001

Houston Federal Credit Union is a federally insured credit union that offers consumer credit transactions to its members that are secured by dwellings. In connection with these transactions, we offer credit protection insurance where the premiums are added on a periodic basis. In order to afford sufficient time to clarify the rule, namely under what circumstances credit insurance premiums may be charged periodically in connection with credit transactions secured by a dwelling, we fully support the Consumer Financial Protection Bureau’s (“CFPB”) proposal to temporarily delay the June 1, 2013 effective date. We would suggest that new effective date be sufficient for creditors to implement changes, especially in light of any adjustments that must be made through data processing providers.