Banning penalties altogether could cause all borrowers, including those who do not prepay, to bear the full cost of investors' prepayment risk, which could raise questions of fairness, and it could reduce consumer choice. We recognize there are differing views on this and look forward to gaining those perspectives through the comment process.
Steering I have so far discussed the elements of our proposal that would seek to ensure that underwriting practices and loan terms on higher-priced loans do not present unwarranted risks to consumers.