I have always been a consumer advocate. Compliance and consumer advocacy are cemented together. We simply can't have one without the other. However, sometimes a zealous regulator can go too far, even for the best of reasons. Remember the Mortgage Rate Tool? It's still up! The rates used are derived from Informa Research Services. The Bureau has this explantion: "The data is provided by Informa Research Services, Inc., Calabasas, CA. www.informars.com. Informa collects the data directly from lenders and every effort is made to collect the most accurate data possible, but they cannot guarantee the data's accuracy." Not sure about that last part, where "they cannot guarantee the data's accuracy." But I am certainly sure that accuracy is virtually guaranteed when it comes to disclosure of the Annual Percentage Rate, given the statutory redisclosure, curing requirements, and civil monetary penalties for violations. Remember back in January, a year after the Consumer Financial Protection Bureau (Bureau) implemented many of its mortgage rules, when Director Richard Cordray said that "rash predictions" voiced during the rulemaking process didn't happen?
He said that the Bureau had not seen ...
"dramatic changes as some had feared. I recall seeing some
rash predictions
, such as that the price of mortgages would double and the volume of mortgages could be halved. But by the time these rules went into effect, lenders had already retreated from the worst sorts of lending that took us into the financial crisis." (My emphasis.)
So, preying lenders "took us into the financial crisis?" |
