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.
March 1, 2016On Tuesday, March 1, 2016, CBA and other trades sent a letter to congressional leadership urging them to restore and extend the one-year protection from foreclosure for military personnel leaving active duty under the Servicemembers Civil Relief Act (SCRA). At the end of 2015, the one-year protection from foreclosure reverted back to 90 days, leaving many institutions concerned about being forced...
February 22, 2016February 22, 2016 Office of the Comptroller of the Currency Legislative and Regulatory Activities Division Attn: 1557-NEW 400 7 th Street SW Suite 3E-218; Mail Stop 9W-11 Washington, DC 20219 PRAInfo@occ.treas.gov Dear sir or madam: The American Bankers Association (ABA) [1] , Consumer Bankers Association (CBA) [2] and National Association of Affordable Housing Lenders (NAAHL) [3] (collectively,...
February 22, 2016On Monday, February 22, 2016, CBA and other associations responded to the OCC’s request for comment on higher loan-to-value (LTV) lending in communities targeted for revitalization. The purpose of the request for comment is to fulfill the Paperwork Reduction Act requirements pursuant to the Draft Bulletin: Risk Management Guidance for Higher Loan-to-Value Lending in Communities Targeted for...
February 18, 2016On Thursday, February 18, 2016, the CFPB issued file specifications for the Home Mortgage Disclosure Act (HMDA) collection for 2017 and 2018. This resource for HMDA filers outlines the fields to be reported annually and explains how each field should be reported under the final HMDA rule. Beginning in 2017, HMDA data will be submitted electronically, but will include the data reported prior to...
February 10, 2016Nearly eight years after the financial crisis, instances of misconduct across the spectrum of the industry continue to be reported in the press with troubling frequency. The coverage strikes an uncomfortable contrast with the intensity of effort the industry and the regulators have focused on reforming and remediating the weaknesses the crisis brought to light. Overall, this environment has...
February 10, 2016On Wednesday, February 10, 2015, the CFPB published a notice in the Federal Register to correct a typo regarding tolerances for property taxes and certain other property-related costs. The error was found in the “Supplementary Information” to the TILA-RESPA Integrated Disclosure rule. According to the CFPB’s addendum, the supplementary information to the TILA-RESPA Final Rule, which was released...
February 2, 2016This week, the CFPB announced an upcoming webinar hosted by the Federal Reserve which will address specific questions related to the Know Before you Owe mortgage disclosure rule and construction lending. The webinar will take place on Tuesday, March 1, 2016, at 2 p.m. EDT.
January 29, 2016January 29, 2016 The Honorable Richard Cordray Director Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Dear Director Cordray, The undersigned organizations greatly appreciate the important work of the Consumer Financial Protection Bureau (CFPB) in assisting implementation of the Know Before You Owe (KBYO) Rule. As the industry moves forward in “live” implementation,...
January 29, 2016On Friday, January 29, 2016, CBA President and CEO Richard Hunt joined other banking trade heads in sending a letter to CFPB Director Richard Cordray requesting further clarification on TILA-RESPA Integrated Disclosure (TRID) requirements. The letter was in response to a December 29, 2015 communication from Director Cordray stating banks may correct minor errors and oversights on disclosure forms...Pages
CBA Letter to Capitol Hill to Restore and Extend the SCRA One Year Foreclosure Protection