Submission Number: 00015
Received: 11/15/2010 10:39:41 AM
Commenter: Troy Stang
Organization: Credit Union Association of Oregon
Agency: Federal Trade Commission
Initiative: Mortgage Acts and Practices - Advertising Rule
Attachments: No Attachments
To whom it may concern:
Thank you for providing the opportunity to comment on the proposed FTC rule regarding Mortgage Acts and Practices. The Credit Union Association of Oregon (CUAO) is a trade association representing Oregon state's 82 credit unions.
State chartered credit unions should be excluded from this rule. State chartered credit unions already comply with numerous regulations regarding mortgage lending, the same regulations that federally chartered credit unions, banks and thrifts must comply with. Many of these regulations were designed to combat the issues that the FTC is addressing with these proposed rules. In addition, the Federal Reserve Board currently has numerous proposed regulations out for comment regarding mortgage lending.
Credit unions have a long history of dealing fairly with their members. They provide financial education, and generally aim to be sure members understand the transactions they are engaging in. Credit unions, whether state or federally chartered have never engaged in the practices the FTC is concerned about. There is no compelling reason to regulate state chartered credit unions more heavily than other financial institutions.
The CUAO does recognize that the FTC has a mandate under the Credit CARD Act to regulate mortgage acts and practices, and does not dispute its authority. The CUAO would, however, suggests that the FTC add a provision to its proposed rules that deems state chartered credit unions in compliance with these rules as long as they comply with all mortgage lending rules--both those rules in effect now, and those in effect in the future. Compliance with mortgage lending rules should be determined by the credit union’s primary state regulator.
Thank you for the opportunity to comment on these proposed rules. I would be pleased to discuss these comments, answer questions, or discuss my concerns in greater detail if you so desire.
Credit Union Association of Oregon