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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.
- March 14, 2016March 14, 2016 Monica Jackson Office of the Executive Secretary Bureau of Consumer Financial Protection 1700 G Street NW. Washington, DC 20552 RE: Request for Information Regarding Home Mortgage Disclosure Act Resubmission Guidelines; Docket No. CFPB-2015-0058 Dear Ms. Jackson, The Consumer Bankers Association1 and the American Bankers Association2 (collectively, the Associations) appreciate the...
- March 10, 2016In the next week, Consumer Financial Protection Bureau Director Richard Cordray will make his annual spring appearance before the House Financial Services Committee. His most recent public comments might have provided a preview of what will dominate the discussions during that hearing. In remarks to the Consumer Bankers Association CBA Live conference in Phoenix, Cordray said that the bureau is...
- March 4, 2016The FDIC issued, on Wednesday, March 2, 2015, a Financial Institution Letter clarifying its supervisory expectations in existing guidance for the risk-management practices when banks make the decision to discontinue foreclosure proceedings. “The FDIC continues to encourage institutions to avoid unnecessary foreclosures by working constructively with borrowers and considering prudent workout...March 1, 2016Dear Chairmen Miller, Hensarling and Thornberry, and Ranking Members Brown, Waters and Smith: Our organizations are writing to urge you 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 ninety days and now mortgage...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)  , Consumer Bankers Association (CBA)  and National Association of Affordable Housing Lenders (NAAHL)  (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, 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.