MBA Comment Letter to CFPB on Mortgage Closing Costs RFI
The Mortgage Bankers Association (MBA) appreciates the opportunity to respond to the Consumer Financial Protection Bureau’s (CFPB or Bureau) request for information (RFI) regarding fees imposed in residential mortgage transactions. Promoting affordable and sustainable homeownership and removing barriers to homeownership is a shared goal of MBA and the CFPB. However, the Bureau’s focus on mortgage closing costs is misguided and inaccurately characterizes certain disclosed, required and necessary mortgage-related fees as “junk fees” in its press releases, blogs, circulars, advisory opinions, and public speeches. These statements suggest that the CFPB may have already arrived at predetermined conclusions about the questions in this RFI and the validity of these charges.