CUNA Regulatory Comment Call

June 5, 2009

FTC Advance Notice of Proposed Rulemaking - Mortgage Acts and Practices


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 or to Senior Assistant General Counsel Jeff Bloch at; 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:


  • 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 •
    Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 •
    Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 •
    Luke Martone • Senior Regulatory Counsel • (202) 508-6743 •