16 CFR Parts 317 and 318: Mortgage Acts and Practices Rulemaking #542308-00009

Submission Number:
Jeremy Zager
Sterling Van Dyke Credit Union
Initiative Name:
16 CFR Parts 317 and 318: Mortgage Acts and Practices Rulemaking
While I applaud the intent of the proposed regulations, I must comment as the President/CEO of a start chartered credit union requiring my institution to comply with the act while not requiring banks, thrifts, and federally chartered credit unions to comply because of jurisdiction is both unfair and will unlevel the playing field for financial services. In my opinion, any business which provides a savings, loan or financial service/product should be subject to this act. To leave a group out of the jurisdiction of the act will only allow for further abuse of the consumers of this nation. Millions of Americans were adversely affected by the actions of banks and thrifts who promoted financial products which benefited their bottom lines instead of the consumers. Our government should take the steps to ensure this never happens again. Financial products and services are a necessity in today's economy and it is in the best interest of all to have safe products which the consumer understands. Personally, I am not opposed to this regulation because I believe the products and services offered by my state chartered credit union are fair and presented in a way which benefits our members. My only objection is as currently presented, I would be regulated for doing what I know and believe to be the right thing while my competition is exempt and can continue to take advantage of the American public.