Tag Archives: CFPB

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AFR Comment Letter to CFPB on High Cost Mortgage Loans

AFR submitted a comment letter to the CFPB on their proposed rules implementing Dodd-Frank changes regarding high cost mortgage loans. The letter argues against changing triggers for high cost loans for smaller loans ­ which the statute allows but does not require, and argues that the proposal should be strengthened in various ways, including by making sure that borrowers in revolving lines of credit get the same protections as those in closed end mortgages.

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Sign on Letter: Support CFPB’s Overseas Remittances Rule

AFR signed onto a letter supporting the CFPB’s overseas remittances rule, which requires remittance transfer providers to provide essential information to consumers about the actual amount of money to be received by their family in the foreign country. The rule makes remittance providers liable for agents acting on their behalf and includes an error resolution procedure to resolve problems.