CUNA supports the Department of Veterans Affairs’ (VA) review of its regulation involving VA-Guaranteed Home Loans, but urges the VA to ensure it has conducted adequate outreach prior to making any changes in this area. CUNA responded Monday to a VA advanced notice of proposed rulemaking (ANPR) on possible revisions to the allowable charges and fees associated with VA-Guaranteed Home Loans.
“We appreciate VA’s initiative to determine whether it can improve the protections afforded veterans as they work through the homebuying process,” the letter reads. “We urge VA to ensure it has a complete picture of the current harms and benefits associated with the existing regulation governing VA-Home Mortgage Loans before it proceeds with a formal rulemaking.”
While CUNA supports the efforts to review the regulation—as well as the decision to issue an ANPR—it believes the VA should measure the current benefits against any improvements that could be achieved by revising it and any potential unintended consequences that might follow.
“Our emphasis on adequate outreach should in no way be misconstrued as a lack of concern for appropriate protections for our veterans,” the letter reads. “We are fully supportive of VA’s review of the current regulation. However, as has been apparent with several recent major financial rulemakings—specifically regarding mortgage loans—it is more important and financially prudent to ensure all relevant information has been obtained prior to embarking on a formal rulemaking.
“Such an approach is much more favorable for both financial institutions and consumers than an approach that involves rushing a rulemaking only to then being forced to ‘clean it up’ through subsequent amendments and interpretive guidance,” the letter adds.