Final Summary of Discussion

By the Regulation Room team

Final Summary Introduction

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§1. Background

Regulation Room is an open government pilot project aimed at increasing the breadth and quality of public participation in the rulemaking process. It is a collaboration between the Cornell eRulemaking Initiative (CeRI), which owns, designs, and operates the site, and federal agencies, including the Consumer Financial Protection Bureau (CFPB).

From August 10 to October 9, 2012, people could use Regulation Room to learn about and discuss two new proposed rules the “2012 Truth in Lending Act (Regulation Z) Mortgage Servicing and the “2012 Real Estate Settlement Procedures Act (Regulation X) Mortgage Servicing Proposal.” This time frame coincided with the official comment period for the rule, which closed October 9, 2012.

On October 3, 2012, the Regulation Room team posted Draft Summaries of the discussion. All users who registered and/or commented on the rules were invited by email to review the drafts and suggest additions or changes until October 9, 2012. In that time, 635 unique visitors visited the site and 2 commenters posted 6 suggestions. The team reviewed all suggestions and then prepared the Final Summaries.

On October 9, these Final Summaries were submitted, via Regulations.gov, to CFPB as a formal public comment in the rulemaking. You can view a pdf of all the summaries as they were submitted to CFPB. (For more on the legal significance of this, see the FAQs.) Registered users received an email notifying them that the Final Summary had been posted on the site and submitted to CFPB.

Anyone could also submit an individual comment directly to CFPB on the proposed rule by visiting Regulations.gov (link directly to the Regulation Z and Regulation X proposals) before midnight on Tuesday, October 9, 2012.

Materials from the Discussion Phase, including the Draft and Final Summaries, will remain available on Regulation Room for public review. A file of all content submitted by users will be made available to CFPB at its option. (This file will not include any personally identifiable information users did not choose to make publicly viewable on the site. See Privacy & Conditions.)

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§2. Who participated?

During the 60 days the rules were open on Regulation Room, a total of 8,908 unique visitors came to the site. There were 12,665 total visits, with people spending an average of 3.04 minutes on the site. Of the issue posts, the average time on the page was longest for “For Borrowers in Trouble: Options for Avoiding Foreclosure” (3.43 minutes) and shortest “For All Borrowers: Getting Errors Fixed” (2.11 minutes). The pages featuring the two Notice of Proposed Rulemakings were viewed a total of 1,111 times with an average time on page of 2.23 minutes and the Regulatory Impact Analyses were viewed 91 times with an average time on page of 2.41.minutes Anyone could read material on the site, but registration was required to participate in the discussion, 144 people registered during the time the rule was open.

Based on answers to a survey when a person made their first comment, 79 % of those who commented said that they had never previously submitted a comment in a federal rulemaking. A second survey question asked people to best describe their interest in the proposed rules. Three main categories could be chosen (consumer, mortgage industry, miscellaneous)

I’m a consumer: 59 people chose this interest category. They were asked to further describe their interests, those interest categories are listed below. People could select more than one of the following categories, which is why the numbers add up to more than 59.

  • 36 – who got, or refinanced, a mortgage in the past 10 years
  • 22 – who had a hard time, or someone in their family, had a hard time making mortgage payments
  • 23 – whose household makes less than $100,000 per year
  • 12 – who had, or someone in my family, has had a mortgage foreclosed
  • 2 – who expect to be a first-time home buyer in the next few years
  • 9 – other; further described as:
    • Currently disabled, but expect to be working in future. We rent out the house we own, and live with family until I’m recovered. Yes, I was affected by the 2008 dip: I was laid off, along with hundreds of others.
    • I had forcedplace insurance placed due to an erroneous determination by my bank about the requirement for flood insurance
    • i was in the early stage of the financial crisis and all in all ended with short sale.
    • someone in my family expects to be a first time home buyer in the next few years
    • student
    • There are problems with servicers and document custodians, stealing or losing personal original documents, and unethical bookeeping methods. I had 2 servicers at the same time for 18 months both posting different amounts to their ledgers on my account.
    • Went through bankruptcy, kept house

I’m in the mortgage industry (real estate agent, mortgage broker, etc.): 31 people chose this interest category. They were asked to further describe their business and customers. People could select more than one of the following categories, which is why the numbers add up to more than 31. My business is best described as:

  • 10 – regulatory compliance officer
  • 8 – mortgage servicer
  • 7 – mortgage originator
  • 2 – real estate agent
  • 2 – mortgage owner
  • 8 – other; further described as:
    • attorney
    • bank
    • community banker
    • credit union
    • federal credit union
    • internal auditor
    • underwriter, forensic auditor
    • whistleblower

The company I work for is best described as having customers who are:

  • 17 – mostly from the local community
  • 4 – mostly from a single state
  • 2 – mostly from a small number of states
  • 6 – from all over the country and/or other countries

Miscellaneous (research, non-profit, government, etc.) – 18 people chose this interest category. They were asked to further describe their interest. People could select more than one of the following categories, which is why the numbers add up to more than 18.

  • 6 – I’m a researcher
  • 5 – I’m affiliated with an advocacy group
  • 2 – I work for a non-profit credit-counseling organization
  • 1 – I work for a state, local, or tribal government
  • 6 – Other: further described as:
    • undefined
    • consumer and reporter
    • foreclosure defense strategies
    • credit attorney
    • former employee of Balboa insurance group turned whistleblower
    • lawyer

NOTE: Regulation Room does not attempt to check whether people correctly identify their interests. For this reason, whenever the summary states a commenter’s interest, the description is based solely on information given by the commenter.

Of the 144 people who registered while the discussion was open, 67 people posted 236 comments. Site moderators posted a total of 109 responses. Comments by users were distributed as follows (these totals do not include moderator posts):

  • For All Borrowers: Who’s Servicing Your Loan? 27 comments by 15 people
  • For All Borrowers: Periodic Statements: 46 comments by 13 people
  • For All Borrowers: Asking For, and Getting, Information: 38 comments by 15 people
  • For All Borrowers: Getting Errors Fixed: 9 comments by 5people
  • For All Borrowers: Adjustable Rate Mortgages: 10 comments by 8 people
  • For Borrowers in Trouble: “Early Intervention” Help: 14 comments by 10 people
  • For Borrowers in Trouble: Reliable Contact with People Who Can Help: 20 comments by 10 people
  • For Borrowers in Trouble: Options for Avoiding Foreclosure: 31 comments by 14 people
  • For Borrowers in Trouble: Partial Payments: 10 comments by 6 people
  • For Borrowers in Trouble: “Force-Placed” Insurance: 31 comments by 12 people

Two other people who did not comment elsewhere on the site endorsed comments.

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§4. Link to survey

Please take a few minutes to fill out this SHORT survey about your Regulation Room experience, it should take less than 10 minutes. Your feedback is important to our work in expanding public understanding and meaningful participation in government policymaking. To show our appreciation for your help, two people who respond by November 1 will receive $50 gift certificates to Amazon.com.

Thank you for participating

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