CUNA Regulatory Comment Call

June 5, 2009

FTC Advance Notice of Proposed Rulemaking - Mortgage Acts and Practices

EXECUTIVE SUMMARY

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Deputy General Counsel Mary Dunn at mdunn@cuna.com or to Senior Assistant General Counsel Jeff Bloch at jbloch@cuna.com; or mail them to Mary or Jeff in c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, 6th Floor, Washington, DC 20004. You may also contact us if you would like a copy of the ANPRs or you may access them on the Internet at the following addresses:
http://www.ftc.gov/os/2009/05/R911004mortgageacts.pdf

http://www.ftc.gov/os/2009/05/R911003mortgageassistance.pdf

QUESTIONS TO CONSIDER REGARDING THE FTC ADVANCE NOTICE OF PROPOSED RULEMAKINGS

  • Do you agree that any rules the FTC develops in this area should not apply to state-chartered credit unions or would that depend on the acts or practices that would be restricted or prohibited?
















  • Are there any specific acts or practices that should be prohibited or restricted in new FTC rules with regard to advertising, marketing, loan originations, appraisals, and servicing for mortgage loans? If so, are there specific types of loans that they should apply to or should they apply to all loans? What would be the benefits of these restrictions or prohibitions?
















  • Are there specific acts or practices that should be prohibited or restricted with regard to those who offer loan modification and foreclosures rescue services to consumers? These may include banning the collection of fees in advance, other restrictions on fees, requirements with regard to refunds, requiring written contracts and disclosures, providing consumers with the right to cancel in certain circumstances, and banning the transfer of the title to the home? To what extent do you provide or advertise loan modification services?
















  • Other comments?
















    Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
    Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
    Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
    Luke Martone • Senior Regulatory Counsel • (202) 508-6743 • lmartone@cuna.com