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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 8, 2022 - 2:00PMUpcomingMay 19, 2022 - 2:00PMUpcomingMay 3, 2022 - 2:00PMPastApril 26, 2022 - 12:00PMPastMarch 23, 2022 - 2:00PMPastJanuary 21, 2022Ladies and Gentlemen: The American Bankers Association, Consumer Bankers Association, Housing Policy Council, and Mortgage Bankers Association (collectively, the Associations), on behalf of our respective members, appreciate the opportunity to respond to the Consumer Financial Protection Bureau’s (the Bureau) Request for Information (RFI) to inform the Bureau on a planned assessment of the 2015...December 14, 2021 - 2:00PMPastNovember 16, 2021 - 1:00PMPastNovember 2, 2021 - 12:00PMPastNovember 1, 2021Hybrid appraisals, also known as bifurcated or desktop appraisals, have a decades long track record of reliability. This type of appraisal has the subject’s inspection completed by someone other than the appraiser, commonly referred to as a bifurcated process. The inspection results are then shared with the appraiser who does the analysis and estimates the type of value required by the client...