CRL Comment to CFPB on Ability to Repay Standards under the Truth in Lending Act (Regulation Z)
Published: February 25, 2013
The Center for American Progress, Center for Responsible Lending, Consumer Federation of America and the National Council of LaRaza respond to the Consumer Financial Protection Bureau proposal on the Ability to Repay Standards. The allies offered specific practices to ensure affordable access to mortgage credit.
Two specific issues formed the crux of their concerns: How mortgage lending compensation is defined and preserving lending programs that offer a gateway to safe and affordable credit. The mortgage compensation concerns heavily focus on yield spread premiums (YSPs).