CBA Joint Letter to CFPB Director Cordray on Implementing Mortgage Rules

Dear Director Cordray:
The Consumer Bankers Association, the American Bankers Association, The Financial Services
Roundtable3 and its Housing Policy Council4 (collectively, the “Associations”) respectfully submit
to the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) this letter on complying with
the Bureau’s new mortgage rules. In order to ensure the new rules achievope their intended
consumer protection goals and avoid the real risk of impairing housing credit availability, the
Associations respectfully urge the Bureau (i) to identify, prioritize and publish necessary
clarifications of the mortgage rules’ application as expeditiously as possible so the fundamental work of system changes can proceed; and (ii) to extend compliance deadlines to assure
effective and efficient implementation of the new requirements and interpretations across
what is undeniably a re‐invention of the entire residential mortgage market.

We first want to take this opportunity to thank you and the CFPB for the manner in which the
Bureau has carried out its mandate under the Dodd‐Frank Act. The CFPB has regularly met with
the industry to maintain open lines of communication during the entire rulemaking process,
and the Bureau has made itself available for additional discussions about its intentions in
crafting these rules. Moreover, once the final rules were issued, the CFPB – in recognition of
the inherent difficulties with implementing these rules under the tight one‐year time frame –
took the extra step to form an implementation team to support the industry’s compliance

To read the full Comment Letter, download the PDF.