“NRMLA believes that it and the FTC have a shared best interest in providing consumers with accurate and non-misleading information to facilitate informed decisions,” said Peter Bell, President of NRMLA in the letter.
The association also suggested several revisions to the proposal that would help consumers identify communications relating to reverse mortgages at the outset and prevent deceptive advertising and allow informed decisions by consumers. Additionally, the letter asks the FTC to require any commercial communication offering reverse mortgages “to state the role of the entity making the communication and their purpose for collecting information about the prospective borrower.”
“NRMLA believes that this modification to the Proposed Rule would allow consumers to better understand the different parties involved with a reverse mortgage loan,” said the letter.
The association also said it believes there should be consistency between the terms and application of the proposed rule and the Federal Reserve’s amendments to Regulation Z, which aims to protect misrepresentations in connection with reverse mortgages.
Comments from the Mortgage Bankers Association goes one step further and asks the FTC to “postpone its rule-making on mortgage advertising and, instead, engage in a coordinated rule-making on the subject with the Consumer Financial Protection Bureau.”
The letter stresses that the FTC, Federal Reserve Board and the CFPB should work together to implement “one set of rules,” not separate and distinct rules with the same purpose of consumer protection.