NRMLA Comments on BFCP Consumer Education Initiatives

The Bureau of Consumer Financial Protection should provide consumers with more information about retirement planning and the role of home equity in funding longevity, but it should first  consult with subject matter experts who can verify the accuracy and clarity of such materials before they are published, according to comments submitted by NRMLA this week.

NRMLA responded to a Request for Information published by the BCFP on April 4 that sought public feedback on the overall efficiency and effectiveness of its consumer financial education programs.

“Home equity must be part of the conversation regarding senior’s retirement plans and planning, and the Bureau should further include this concept in its consumer education materials addressed and directed toward seniors,” commented NRMLA.

However, before publishing anything on reverse mortgages, or any specialty field, Bureau officials should first consult with, and consider input, from industry experts.

NRMLA highlighted the August 2017 publication of Issue Brief: The costs and risks of using a reverse mortgage to delay collecting Social Security. The report evaluated the financial impact of using HECM loan proceeds to bridge the gap in income while delaying Social Security benefits until a later age, but was roundly criticized by well-recognized financial planning experts and academics.

“While we understand that reasonable minds can differ, the crux of this matter for NRMLA and its members is that neither former-Director Cordray now any of his staff reached out to industry members prior to the CFPB publishing this very inaccurate and ill-informed issue brief,” said NRMLA.

The complete letter is posted to the NRMLA Comment Letters page on, where you can find NRMLA’s comment letters to federal agencies dating back to July 2016. This page is restricted to members only and you must be logged in to view it.