“[It] inaccurately characterizes certain disclosed, required and necessary mortgage-related fees as ‘junk fees’ in its press releases, blogs, circulars, advisory opinions, and public speeches,” said Broeksmit. “These statements suggest that the CFPB may have already arrived at predetermined conclusions about the questions in this RFI and the validity of these charges.”
The MBA also highlighted that mortgage lenders have faced eight consecutive quarters of net production losses, challenging the CFPB’s narrative that lenders benefit from high closing costs.
The association highlighted several factors contributing to increased closing costs:
- Rising third-party service fees, many of which are required for loan securitization or guarantees.
- Decreased loan pull-through rates, resulting in lenders bearing more costs when borrowers do not close transactions.
- Increased credit reporting fees, even during a time of decreased origination volume.
The association suggested that instead of focusing on closing costs, the CFPB should consider revising existing regulations that add to these costs.
Among the recommendations were changes to the Loan Officer Compensation Rule and the TILA-RESPA Integrated Disclosure (TRID) rules, which the MBA argues could help reduce compliance costs and provide clearer disclosures to consumers.
Source: mpamag.com