The purpose of that document was to seek comment on whether the Bureau should delay the August 19, 2019 compliance date for the Mandatory Underwriting Provisions as the Bureau indicated in the Delay NPRM. The Bureau failed to propose to wait the conformity date for the other conditions associated with the 2017 Final Rule, including the Payment Provisions. 63
However, numerous commenters addressed problems linked to payments or even the range associated with the Rule more generally in their remark letters
a quantity of commenters, including lenders, trade associations, tribal governments, the SBA OA, as well as others, asked for that the Bureau: (1) Delay the conformity date for the re re Payment conditions or for the Rule all together; (2) make improvements to your re re Payment Provisions or revise the range of covered loans or entities to that the Rule is applicable; and/or (3) rescind the whole Rule. In addition, a few commenters advised that the Payment conditions must certanly be reassessed in light associated with Reconsideration NPRM’s proposed way of unfairness and abusiveness, asserting that the re re re Payment Provisions are based on the 2017 Final Rule’s way of unfairness and abusiveness, that the Reconsideration NPRM preliminarily deemed problematic.