The Finance Commission of Texas and the Texas Credit Union Commission (“Commissions”) jointly propose amendments to Interpretations 7 TAC §§ 153.22, 153.51, and 153.84 relating to interpretations of Sections 50(a)(6), (g), and (t)(3), Article XVI, Texas Constitution, regarding home equity lending on Texas homestead. These proposed amendments are published for comment in the March 14, 2008 issue of the Texas Register (Vol. 33, No. 11). Written comments on the above proposed amendments may be submitted to Betsy Loar, General Counsel, Texas Credit Union Department, 914 East Anderson Lane, Austin, Texas 78752-1699, or to Sealy Hutchings, General Counsel, Office of Consumer Credit Commissioner, 2601 North Lamar Boulevard, Austin, Texas 78705-4207 or by email to [email protected] or [email protected] state.tx.us. Written comments on the proposed amended interpretations must be received on or before April 13, 2008. After that date, no further written comments on the proposed amended interpretations will be considered or accepted by the Commissions. We urge our clients who make home equity loans secured by Texas homesteads to review the proposed amended interpretations and submit written comments before April 13, 2008. This is your opportunity to influence Texas home equity law to your benefit. We will be sending our comments to the Commissions in the near future, as we are concerned with several of these proposed amended interpretations. The text of the proposed amended interpretations as published in the Texas Register is attached. Underlined language indicates additions and bracketed language with strikethroughs indicates deletions.

Complete Memorandum