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Empire Justice and Organizations Want Consumers Protected When Shopping for a Mortgage

December 12, 2012


The undersigned consumer, legal services, civil rights and community organizations hereby submit the following comments on your proposed regulations regarding the combined TILA RESPA disclosure, the revised TILA finance charge, and, under a separate docket, HOEPA coverage as affected by the proposed changes to the finance charge, annual percentage rate (APR) and Transaction Coverage Rate.

In brief, we support the proposal to require all fees and charges to be included in the APR that consumers are quoted when they shop for a mortgage, and the proposed disclosure forms are generally an improvement. However, we have three significant concerns:

  • The decision to bury the APR on page three will make it less likely that consumers will understand or be able to compare the full cost of different mortgages, and more likely that unscrupulous lenders will quote misleadingly low interest rates with high hidden fees.
  • Consumers should never be given written estimates on which they cannot rely.
  • All high-cost loans should receive special protections even if the loan is high cost due to fees and charges that are newly included in the APR.

Read Full Comment Letter

For more information, please contact:

Barbara van Kerkhove

Empire Justice Center
Telesca Center for Justice
One West Main Street, Suite 200
Rochester, NY  14614

(585) 454-4060
(585) 454-2518