Product: Mortgage

CFPB 's decision to close case # XXXX, based on Mr. Cooper 's response is in direct violation of CFPB 's own ruling, ************************************************ BUREAU OF CONSUMER FINANCIAL PROTECTION 12 CFR Part 1002 [ Docket No. XXXX ] XXXX XXXX " Disclosure and Delivery Requirements for Copies of Appraisals and Other Written Valuations Under the Equal Credit Opportunity Act ( Regulation B ) '' *** I draw your attention to pages 2, 23 and 27-28 : *************************************************************************************************** Page 2 : " Require creditors to notify applicants within three business days of receiving an application of their right to receive a copy of appraisals developed. Require creditors to provide applicants a copy of each appraisal and other written valuation promptly upon its completion or three business days before consummation ( for closed-end credit ) or account opening ( for open-end credit ), whichever is earlier. '' ************************************************************************************************** Page 23 : " reference to the existing provisions of Regulation B.32 To the extent a loss mitigation transaction is covered by Regulation B, the transaction is covered by the final rule, including its requirement of providing copies of appraisals and other written valuations. Consumers generally will benefit from receiving information about the value of their dwelling, both in the context of making a decision about the loss mitigation transaction and also in detecting potential discrimination, consistent with the purposes of ECOA. The Bureau believes these benefits outweigh the cost to the creditor of providing copies of documentation that the creditor already has received. For the reasons discussed in the Bureaus analysis under section 1022 ( b ) below, the Bureau believes the per-loan cost of providing copies of these materials is modest, and they will often be provided in electronic form. The Bureau is therefore not exercising its exception authority to exempt loss '' ************************************************************************************************** Pages 27-28 : " reference to the existing provisions of Regulation B.32 To the extent a loss mitigation transaction is covered by Regulation B, the transaction is covered by the final rule, including its requirement of providing copies of appraisals and other written valuations. Consumers generally will benefit from receiving information about the value of their dwelling, both in the context of making a decision about the loss mitigation transaction and also in detecting potential discrimination, consistent with the purposes of ECOA.

The Bureau believes these benefits outweigh the cost to the creditor of providing copies of documentation that the creditor already has received. For the reasons discussed in the Bureaus analysis under section 1022 ( b ) below, the Bureau believes the per-loan cost of providing copies of these materials is modest, and they will often be provided in electronic form. The Bureau is therefore not exercising its exception authority to exempt loss '' Based on this regulation, the CFPB should not abide by or condone Mr. Cooper 's decision to again deny us the report.