Customer advocacy groups noted the Delay NPRM illustrates the magnitude of problems for customers through its estimate regarding the great things about wait to loan providers.

Customer advocacy groups noted the Delay NPRM illustrates the magnitude of problems for customers through its estimate regarding the great things about wait to loan providers.

A customer advocacy team commented that, based on the findings within the 2017 Final Rule, the required Underwriting Provisions would provide significant advantages to customers, decreasing the harms, identified above, that customers would otherwise suffer. A person commenter argued that the Delay NPRM had been arbitrary and capricious as it just took under consideration the expense to industry of complying using the 2017 Final Rule and completely ignored the advantages to people that would be a consequence of conformity.

Consumer advocacy groups asserted that delay regarding the Mandatory Underwriting Provisions would cause serious, irreparable injury to customers, and that customers cannot manage to wait one more 15 months when it comes to relief that the Mandatory Underwriting Provisions would offer. These harms, in line with the commenters, could be considerably curbed by the Mandatory Underwriting Provisions, but would carry on throughout the 15 months of this proposed delay, causing many people and families to see long-lasting and spiraling harms.

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