Today's housing crisis was made possible by weak rules and poor enforcement. As policymakers consider regulatory reform, we focus on three broad goals: stronger rules to restore common sense standards; preserving the states' ability to protect its citizens from predatory lending; and more disclosure and transparency among lenders.
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- Comparing Dual Track Foreclosure Restrictions
June 13, 2013
CRL compares the dual track foreclosure restrictions and requirements in the National Mortgage Settlement, the California Homeowner Bill of Rights and related rules from the Consumer Financial Protection Bureau.
- CRL Comment to CFPB on Amendments to 2013 Mortgage Rule
June 3, 2013
- Consumer Advocates Urge FHFA to Curb Lender-Placed Insurance Problems
May 28, 2013
In this comment to the Federal Housing Finance Agency (FHFA), CRL and seven allies comment on proposed practice limitations and broader recommendations regarding lender-placed insurance (LPI). LPI markets are characterized by reverse competition in which LPI premiums paid by mortgage servicers and LPI amounts subsequently charged to borrowers and investors areinflated because LPI insurers/vendors compete for the servicers’ business by providing considerations – kickbacks – to the servicers and including the cost of these considerations in the LPI premiums and LPI amounts charged to borrowers and investors. The extent of the overcharges is demonstrated by the very low loss ratios (claims incurred divided by premiums earned) of LPI compared to loss ratios for homeowners insurance. LPI charges to borrowers and investors are at least twice the reasonable cost of providing LPI. In addition, excessive LPI charges to borrowers and the government-sponsored enterprises (GSEs) are a source of servicer-induced foreclosures, and such excessive charges are also inconsistent with the mission and affordable housing goals of the GSEs. For these reasons, CRL and its allies support the direct purchase by GSEs of LPI and insurance tracking services and support prohibitions against kickbacks from LPI insurers/vendors to mortgage servicers.
- Consumer Advocates Urge HAMP Extension
March 26, 2013
National and statewide consumer groups are urging that the Home Affordable Modification Program (HAMP) be extended, citing success in foreclosure prevention and modification.
- Analysis of the Report of the Monitor of the National Mortgage Settlement
March 20, 2013
CRL's analysis of "Ongoing Implementation",a report on 2012 efforts under the National Mortgage Settlement to halt foreclosures through loan modifications, and other assistance.