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MCUA Comments on CFPB Proposal on Ability to Repay

The Consumer Financial Protection Bureau (CFPB) has already adopted a final rule to implement the ability to repay provisions regarding closed-end mortgage loans under the Dodd-Frank Act. The rule takes effect January 10, 2014. However, the agency is also seeking comments, through today, February 25, on a proposal that would allow some creditors to have more flexibility in complying with the rule. The Missouri Credit Union Association (MCUA) sent a comment letter today, February 25, 2013.  Click here to read a copy of the letter.

MCUA has filed a strong letter with the CFPB on this proposal urging that:

  • All credit union mortgage lenders be exempt from the ability to repay provisions; and
  • In the alternative, all credit unions that are either CDFIs or Low-Income Designated Credit Unions should qualify for the exemption.