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Consumer Financial Protection Bureau

ALTA Joins Letter Urging CFPB to Drop ‘All In’ APR Proposal

September 11, 2012

In a joint letter with 15 other associations, ALTA encouraged the Consumer Financial Protection Bureau to drop its proposed so-called “All In” annual percentage rate (APR), which would eliminate many exemptions to the calculation for residential mortgages.

According to the letter, the current APR does not provide value to the consumer and does not serve as an accurate shopping tool. The Bureau’s research indicates that consumers confuse the APR with the note rate.

“This confusion has nothing to do with what is in or out of the APR calculation,” ALTA wrote in the letter. “Simply adding additional fees … will add significant costs and complications to the rulemaking effort, with no measureable benefit to the borrower.”

Deadline to provide comment to the CFPB regarding the “All In” APR has been extended to Nov. 6. ALTA is working on its own letter regarding concerns about the APR proposal.

For more information, contact Steve Gottheim, ALTA’s legislative and regulatory counsel

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American Land Title Association
1800 M Street, NW, Suite 300S
Washington, D.C. 20036-5828
P. 202.296.3671 F. 202.223.5843
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