Comment from Jean-Louis, Xavier

I am a graduate accounting student at the University of Illinois with a background in economics and property management. I also follow mortgage and real estate markets closely. I am writing in response to Questions 8 and 9. Question 8: Materiality-based standards I support adding a materiality standard as a supplement to the current timing rules. I do not support replacing the timing rules completely. The three-business-day review period gives borrowers time to review the final terms before closing. This protection should remain when an important term changes, such as the APR increasing beyond the permitted tolerance, the loan product changing, or a prepayment penalty being added. The CFPB should create a clear and narrow list of non-material changes that would not restart the waiting period. For example, a small fee correction that lowers the borrower’s total cost should not delay the closing. Such delays increase costs without giving the borrower a meaningful benefit. This approach would protect borrowers when an important term changes while reducing delays caused by minor corrections. Clear definitions would also help lenders apply the standard consistently. Question 9: Rescission and refinance timing The three-day review period before closing and the three-day rescission period after closing create close to one week of delay for some refinance transactions. For a basic rate-and-term refinance that lowers the borrower’s interest rate or monthly payment without increasing the principal balance, reducing this overlap makes sense. I do not support the same treatment for cash-out refinances. A cash-out refinance increases the debt secured by the borrower’s home and places more home equity at risk. The three-day rescission period gives the borrower time to reconsider this larger financial decision. I recommend limiting any shorter waiting period to rate-and-term refinances that do not increase the borrower’s principal balance, except for reasonable closing costs. Cash-out refinances should keep the full rescission protection. Thank you for considering my comments. Xavier Jean-Louis