The RFI includes a variety of questions regarding timing requirements for TRID disclosures, fee disclosure tolerance thresholds, how borrowers’ right of rescission impacts refinances and issues involving reverse mortgages.
CHLA suggested the facility be modeled after the pass-through assistance program Ginnie launched in 2020 to support servicers facing liquidity shortfalls due to pandemic-related borrower forbearances.
Two class-action lawsuits brought forward last month allege the company is trying to circumvent the Truth in Lending Act by claiming HEIs are not loans.