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From: Subject: Comments: American West Mortgage, William C Massey Reg Z - Truth in Lending Date: Dec

From: Subject: Comments: American West Mortgage, William C Massey Reg Z - Truth in Lending Date: Dec 2025

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The document is a comment from William C Massey of American West Mortgage regarding the Regulation Z - Truth in Lending proposal for closed-end mortgages. It expresses concerns about the complexity and implications of the proposal, particularly how it may lead to higher costs and inefficiencies in the lending process. Massey argues that focusing solely on the lowest rates can be misleading, as many transactions involve credits to consumers. He warns that further regulations could hinder competition and recovery in the lending market, suggesting that any changes should apply equally to all financial institutions.

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What year was the Truth in Lending Act?

The Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq., was enacted on May 29, 1968, as title I of the Consumer Credit Protection Act (Pub. L. 90-321).

What is the ability to repay Regulation Z?

Regulation Z currently prohibits a creditor from making a higher-priced mortgage loan without regard to the consumers ability to repay the loan.

What is the ability to repay rule?

Requirements of Ability to Repay The factors determining the borrowers ability to repay include the borrowers current income and assets. They may also include reasonably expected income. The borrower must also provide verification of this income and their employment status.

What is the ability to repay disclosure?

Capacity, one of the most important of all five factors, is how the borrower will pay back a loan. Capacity includes the ability to pay current financial commitments, repay any new debt, provide for replacement allowances, make payments for family living and maintain reserves for adversity.

What Federal Home loan Mortgage Corporation introduced the first security backed by conventional loans in 1971?

The Act also authorized Fannie Mae and Freddie Mac to buy and sell mortgages not insured or guaranteed by the federal government. 28 In 1971, Freddie Mac issued the first conventional loan MBS.

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What month and year did the new mortgage advertising rules under Reg Z take effect?

In July 2008, the Federal Reserve Board issued many new mortgage advertising rules under Regulation Z; these rules took effect on October 1, 2009.

What demonstrate a reasonable ability to repay the loan?

One of the most important and impactful of these new rules is the Ability-To-Repay Rule (the ATR Rule). Under the ATR Rule, mortgage lenders must make a reasonable and good faith determination, based on documented and verified information, that a borrower has a reasonable ability to repay a residential mortgage loan.

From: Subject: Comments: American West Mortgage, William C Massey Reg Z - Truth in Lending Date: Dec 2025

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What year was the Truth in Lending Act?

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What is the ability to repay disclosure?

What Federal Home loan Mortgage Corporation introduced the first security backed by conventional loans in 1971?

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What month and year did the new mortgage advertising rules under Reg Z take effect?

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