We appreciate the complexity of these new regulations based on the revisions to AMTPA. We agree with the Consumer Financial Protection Board (“CFPB”) that the changes made by the
Dodd-Frank Wall Street Reform and Consumer Protection Act4 necessitated the issuance of this Interim Final rule on the first day the CFPB came into legal existence. We also agree with many of
the interpretations of the new AMTPA provided by the CFPB, and we applaud the CFPB’s requirement that all variable rate indexes be beyond the control of the creditor.
However, in several, quite serious, matters the rule misinterprets both the clear language in the new AMTPA and Congressional intent. We urge the CFPB to move quickly to issue a clarifying
Interim Final rule correcting these misinterpretations.