Comment Letters

Comment Letters

CFPB Proposal on HOEPA

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On
July 9, 2012, the CFPB issued a proposed rule that would implement the HOEPA
amendments of the Dodd-Frank Act and fundamentally change the way that Annual
Percentage Rate is calculated.  If adopted "as-is," this will be
one more rule that creates a competitive disadvantage between community banks
and the mega-banks who have the resources to conduct more mortgage loan

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