So on Pearl Harbor Day the CFPB announces Reservists and National Guard members are paying million in extra interest as lenders are not reducing the rates to 6%. It say, if you look quickly, that the CFPB found $100 million of lost interest rate benefits.
Not that $100M was estimated from an 11 year period and it says many lenders "make" the SM request the benefit instead of the lender data scrubbing its records against the DMDC and just reducing the rate. Seems to me the SCRA says the SM is to request it in writing with a copy of their orders. But the CFPB would rather say lenders are not doing what's "right" and I disagree with this.
Welcome to spin city and it is making me dizzy.
Banks are not required to scrub the DMDA files on a periodic basis and reduce rates. The law says the rate is to be requested. They want proactive compliance.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell