The National Consumer Law Center ("NCLC") respectfully submits the following comments on behalf of its low income clients, as well as Americans for Financial Reform, California Reinvestment Coalition, the Center for Responsible Lending, Consumer Action, Consumers Union, National Association of Consumer Advocates, National Community Reinvestment Coalition, National Fair Housing Alliance and the Neighborhood Economic Development Advocacy Project, regarding the Federal Reserve Board's proposals to revise numerous regulations under the Truth in Lending Act ("TILA") governing home-secured lending.
In these comments we address the range of subjects included in this complex docket. We believe that some of the Board's proposals are constructive and will further consumer protections for homeowners, or could do so if revised. However, some of the proposals are extremely damaging to consumers and to preservation of homeownership, and – we believe – are beyond the Board's authority.
Because of the extensive damage that the Board's proposal would cause to consumers seeking to exercise the extended right of rescission, we already have made – and now repeat – the unprecedented request that the Board withdraw this docket. In the face of an unparalleled foreclosure crisis, with foreclosure rates more than three times higher than those in the Great Depression, now is the time to reinforce the fundamental importance of TILA rescission. Instead, the Board has proposed rules aimed at reducing the ?litigation risk? for mortgage companies by eviscerating the single most effective tool that homeowners have to stop foreclosures and avoid predatory loans: the extended right of rescission.