Comment Letter to the Federal Reserve Board Suggesting Improvements to HOEPA Consumer Protections

fed_feb2001_r-1090_hoepa.pdfRespond to the request for comments by the Board of Governors of the
Federal Reserve System on changes to Regulation Z under the Home
Ownership and Equity Protection Act (HOEPA). HOEPA gives the Board
broad regulatory authority over the predatory lending issue.  The
comment letter suggests several improvements to the proposed consumer
protections such as monthly payment disclosure, APR triggers, and
counseling requirements.
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