[Board1] FW: Sample Draft of ALTA CFPB RFI Letter

[George Peters]

FYI, note the deadline. We do have a volunteer and will check with Jim Blair
when he gets back to the office.

 

George

 

George Peters, WTP

Executive Director

Washington Land Title Association

 <https://washingtonlandtitle.com> https://washingtonlandtitle.com 

Mail: PO Box 328, Lynnwood, WA 98046

Delivery: 6817 208th St SW, #328, Lynnwood, WA 98036

206-437-5869 (Mobile)

206-260-4731 (Fax)

 <mailto:execdirector at wltaonline.org> execdirector at washingtonlandtitle.com

 



This is a confidential communication intended solely for the named
recipient. If you are not the intended recipient, please destroy it and call
George Peters at 206-437-5869 immediately. Thank you.

 

From: Caroline Cone <ccone at alta.org> 
Sent: Wednesday, July 17, 2024 1:14 PM
To: Caroline Cone <ccone at alta.org>
Cc: Elizabeth Blosser <eblosser at alta.org>
Subject: FW: Sample Draft of ALTA CFPB RFI Letter

 

All -

 

I wanted to follow up to let you know that the deadline for comments is
Friday, August 2nd: RFI Fees in Residential Mortgage Transactions
(consumerfinance.gov)
<https://files.consumerfinance.gov/f/documents/cfpb_rfi-closing-costs_2024-0
5.pdf> .

 

Thanks!

 

From: Caroline Cone 
Sent: Wednesday, July 17, 2024 3:03 PM
To: Caroline Cone <ccone at alta.org <mailto:ccone at alta.org> >
Cc: Elizabeth Blosser <eblosser at alta.org <mailto:eblosser at alta.org> >;
Christopher Morton <cmorton at alta.org <mailto:cmorton at alta.org> >; Steve
Gottheim <steve at alta.org <mailto:steve at alta.org> >; Kevin Cameron
<kcameron at alta.org <mailto:kcameron at alta.org> >; Emily Tryon
<etryon at alta.org <mailto:etryon at alta.org> >; Leah Shimp Vass
<lshimpvass at alta.org <mailto:lshimpvass at alta.org> >
Subject: Sample Draft of ALTA CFPB RFI Letter

 

State Leaders -

 

As previously mentioned, we wanted to send a sample rough draft of ALTA's
comment letter to the CFPB RFI
<https://www.consumerfinance.gov/rules-policy/notice-opportunities-comment/o
pen-notices/request-for-information-regarding-mortgage-closing-costs/> . If
your state land title association would like to send a comment letter as
well, the attached draft, along with the outline below should be helpful.
Please note, it is very important to highlight the unique aspects of the
title insurance industry in your specific state in letters.  Additionally,
ALTA staff are happy to help with drafting and review of any letters.
Finally, if you can let us know if you plan to send a letter, that would
also be very helpful so we can track submissions. 

 

*	Intro

*	Who you are
*	Why you are writing: To provide CFPB with a deeper understanding of
how title insurance is regulated in STATE. As the CFPB reviews its options
after reading RFI responses, they should understand how state law (which has
supremacy when it comes to insurance) will work with any reforms the CFPB is
considering.
*	Say something about the use of the term junk fee related to title is
wrong and creates issues that will ultimately harm consumers.

*	Background on state regulation of rates

*	How does rate regulation work
*	What factors must be included in rate (risk only or search and exam
too).
*	Beyond premium do companies typically charge a closing or other fee?
*	Provide example of typical costs on $300,000 home sale

*	Background on other relevant state laws

*	Does state have anti inducement law. If so what does it say
*	Does state do market conduct exams and do they have RESPA component
*	Does state limit spending on marketing 

*	Conclusion

*	As CFPB contemplates what to do with the information obtained by RFI
they need to make sure that when it comes to title it works in conjunction
with state law to avoid conflicts.

 

Should you have any questions, please do not hesitate to reach out to us.

 

Thanks,
Caroline

 

Caroline Cone

State Government Affairs Manager

American Land Title Association

Cell: (972) 978-5633| ccone at alta.org <mailto:ccone at alta.org> 

 

 

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