Written communication with consumers obviously leaves an undeniable trail the CFPB can follow to determine unfairness, deception, and abuse. On the other hand, is verbal communication essentially treated as "she said, he said" when it comes to enforcement?

Has the MBA produced a position paper in response to this new focus on "junk fees"? If yes, how can we get a copy of it?

MBA link on letter to CFPB https://www.mba.org/docs/default-source/residential-policy-letters/mba-letter-on-fees-rfi-(final)-4.11.22.pdf?sfvrsn=ddf95f4e_3

Thank you, Brian. Looks like Pete Mills has been busy.

Thanks Brian--you beat me to it! Our letter is the best source for our arguments I discussed and can be found at that link.

You can find the joint trades letter here: https://www.mba.org/docs/default-source/residential-policy-letters/res_pol_letter_joint_trades_response_to_cfpb_fees_rfi_cfpb-2022-0003_april2022.pdf?sfvrsn=1c4806f8_1

Would disclosure of fees by the servicer once a loan is sold / transferred to a new servicer provide any cover / protection

What are your thoughts on lenders increasing appraisal fees after the LE has been disclosed? Some lenders allow this and some do not as a change of circumstance?

You could provide any background to why late fees are being considered late fees?

Thank you everyone, great information!

Fuel charge

Consider junk fees*

Thank you as this was great information.

Thank you for the insight.

Thank you Mitch!

Really appreciate these insights. Thank you, gentlemen and Danielle.

Thank you - very informative!

Thank you All.

Thank you!

Thank you