MBA Letter to FCC on Revocation of Consent under the Telephone Consumer Protect Act
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The Mortgage Bankers Association and its members appreciate the opportunity to offer comments on the Federal Trade Commission’s (FTC’s) Notice of Proposed Rulemaking regarding Unfair or Deceptive Fees.2 The MBA shares the FTC’s commitment to transparent pricing of consumer goods and services, but mortgage lending is already subject to comprehensive disclosure rules, known as Regulation Z, promulgated by the Consumer Financial Protection Bureau (CFPB) under the Truth in Lending Act (TILA), as well as a broad regulatory prohibition, in the CFPB’s Regulation N, on making misrepresentations in relation to a mortgage transaction.
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