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Mortgage and Home Equity
Mortgage and home equity products have received increased regulatory and legislative scrutiny over the past few years. Historically, CBA has focused on home equity as a major retail product of our members. However, the Dodd-Frank Act’s elimination of federal preemption standards previously afforded to operational subsidiaries has forced many depository institutions to internalize their primary mortgage products, making them a more traditional retail issue. CBA is focused primarily on the efforts of the CFPB to regulate in this space, including TILA-RESPA reform, Qualified Mortgage (QM) rulemaking, and Dodd-Frank Title 14 rulemaking.
- June 24, 2020 - 2:00PMUpcomingMay 6, 2020 - 2:00PMUpcomingApril 1, 2020 - 2:00PMPastMarch 9, 2020March 9, 2020 The Honorable Mike Crapo Chairman Committee on Banking, Housing and Urban Affairs 534 Dirksen Senate Office Building Washington, D.C. 20510 The Honorable Sherrod Brown Ranking Member Committee on Banking, Housing and Urban Affairs 534 Dirksen Senate Office Building Washington, D.C. 20510 Dear Chairman Crapo and Ranking Member Brown: The Consumer Bankers Association (CBA) submits the...February 27, 2020 - 1:00PMPastJanuary 21, 2020To Whom It May Concern: The Consumer Bankers Association (“CBA”), the Utah Bankers Association (“UBA”), and the National Association of Industrial Bankers (“NAIB” and collectively, the “Associations”)1 appreciate the opportunity to comment on the Office of the Comptroller of the Currency’s (“OCC”) Notice of Proposed Rulemaking (“NPR”) to amend 12 C.F.R. §§ 7.4001 and 160.110 to clarify...January 10, 2020On, Friday, January 10, 2020, the CFPB granted a no-action letter (NAL) to Bank of America regarding the bank’s funding arrangements with housing counseling agencies certified by the U.S. Department of Housing and Urban Development (HUD). The more than 1,600 HUD-certified HCAs serve more than one million households annually. They offer pre-purchase homeownership counseling to potential borrowers...December 18, 2019Despite the growing interest in digital mortgage originations, mortgage loan cycle time actually grew longer in 2017, to an average of 36 days – an increase of almost a week from the previous year. This increase in loan cycle time means lenders need to look at streamlining other areas of the mortgage process in order to improve profitability and borrower satisfaction. Luckily, there are other...November 20, 2019On Wednesday, November 20, 2019, the Bureau released a Request for Information (RFI) asking for feedback on Integrated Mortgage Disclosures Under the Real Estate Procedures Act and the Truth In Lending Act, as well as certain amendments in accordance with Section 1022(d) of Dodd-Frank. Under the RFI, the Bureau asks for comment on its plan to asses the rule as well as recommendations that may be...October 18, 2019Ladies and Gentlemen: This comment is submitted by the American Bankers Association (ABA),1 the Consumer Bankers Association (CBA),2 and the Housing Policy Council3 (HPC) in response to the August 19, 2019 proposed rule4 of the U.S. Department of Housing and Urban Development (the Department or HUD). The Proposed Rule “follows a June 20, 2018, advance notice of proposed rulemaking, in which...