Submission Number: 00013
Received: 11/12/2010 5:37:17 PM
Commenter: Mary Sroufe
Organization: Washington Credit Union League
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 FTC rule regarding Mortgage Acts and Practices. The Washington Credit Union League is a trade association representing Washington State's one hundred and seventeen credit unions.
The League would like to urge the FTC to exclude state-chartered credit unions from this rule. State chartered credit unions are already subject to the same numerous regulations regarding mortgage acts and practices that banks, thrifts, and federally chartered credit unions are subject to. Financial institutions generally are already subject to a staggering number of regulations surrounding mortgage lending, many of which are designed to combat the issues addressed by these proposed rules.
In addition, credit unions, whether state or federally chartered did not engage in the practices that are prohibited by this proposed rule. Credit unions have, historically, dealt fairly with their members, encouraged members to understand the transactions they were contemplating, and sought to provide the best possible value to their members.
Subjecting one category of financial institution to rules others do not need to comply with, in absence of a compelling reason to do so is neither fair nor warranted.
The League does, however, recognize that the FTC has a mandate under the Credit CARD Act to regulate these matters. The League suggests adding a provision that will deem state credit unions in compliance with the FTC rules as long as they are in compliance with all current and future regulations pertaining to mortgage lending, as determined by their examiner.
Thank you for the opportunity to comment on these proposed rules. Please feel free to contact me if you have any further questions.
Director of Regulatory Affairs
Washington Credit Union League