Maintaining information on language preference over the entire life of the loan is critical because borrowers need to interact with their lenders and servicers at many different times over the life of a loan. Further, we argued that universally used forms like the Uniform Residential Loan Application (URLA) and Uniform Borrower Assistance Form (UBAF) were the logical mechanism to collect such information in order to maintain it over the life of the loan. Nothing articulated in the industry association comments or others echoing their claims has rebutted any of these core arguments.
