Monday, August 14, 2007

Iowa Attorney General Tom Miller

Comments to the Federal Reserve Board of Governors on Adopting Regulations to Prohibit Unfair and Deceptive Acts and Practices under the Home Ownership and Equity Protection Act (HOEPA)

August 14, 2007

On June 14, 2007, Iowa Attorney General Tom Miller testified in Washington before the Board of Governors of the Federal Reserve System regarding the Board’s authority to issue regulations prohibiting unfair and deceptive acts and practices under the Home Ownership and Equity Protection Act (HOEPA). In his testimony, Miller urged the Board to enact comprehensive regulations to help prevent the widespread abuses from happening again that have occurred in recent years in the sub-prime mortgage market.

As a follow-up, on August 14, 2007, Miller submitted formal comments to the Federal Reserve Board. In his comments, Miller warned the Board not to focus only on improving disclosures and urged the Board to issue substantive regulations covering all sub-prime loans.

Specifically, Miller recommended that the Federal Reserve Board:

• require underwriting according to an ability to repay standard;
  
  
• ban prepayment penalties;
  
  
• require escrow accounts for real estate taxes and insurance;
  
  
• severely restrict the use of stated income loans; and
  
  
• prohibit future promises to refinance.

Go to Attorney General Tom Miller -- formal comments to the Federal Reserve Board, August 14, 2007.

For more information: Bob Brammer, Iowa Attorney General’s Office, 515-281-6699

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