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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.
- 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...January 28, 2016On Thursday, January 28, 2016 the CFPB released the latest edition of its Monthly Complaint Report , which focused on complaints in the New York Metro area, as well as those falling into the “other financial services” category. Below are notable takeaways: For three months in a row, the top three “Most Complained about Companies” are credit bureaus, not banks. Prepaid complaints showed the...January 22, 2016Cordray to Offer Keynote at CBA LIVE We are pleased to announce CFPB Director Richard Cordray will join us for CBA LIVE 2016. A man who needs no introduction, Director Cordray will join me on the big stage on Wednesday, March 9, 2016, to discuss all things CFPB. Remember, if you have not registered yet, it is not too late! CBA LIVE 2016: Leadership Unplugged takes place March 7-9 in Phoenix, AZ...January 13, 2016This week, the House Financial Services Subcommittee on Housing and Insurance held two flood insurance hearings entitled: Opportunities and Challenges Facing the National Flood Insurance Program How to Create a More Robust and Private Flood Insurance Marketplace Subcommittee Chairman Blaine Luetkemeyer (R-MO) stated, “With flooding happening from coast to coast, and most recently devastating my...January 12, 2016A coalition of financial services trade associations sent a joint letter to the Federal Housing Finance Agency (FHFA) expressing concern over its proposed survey to borrowers that will collect data for the upcoming National Mortgage Database project. The survey, which mortgage borrowers will be able to fill out on a voluntary basis, is designed to have up to 85 questions regarding their home loan...January 12, 2016On Tuesday, January 12, 2016, CBA joined a coalition of financial services trades in sending a letter to the Federal Housing Finance Agency (FHFA) expressing concern over the agency’s data collection practices as part of its National Mortgage Database Project. The voluntary borrower survey contains 85 questions regarding a customer’s mortgage experience. CBA raised concerns over the intrusiveness...January 12, 2016On Tuesday, January 12, 2016, the CFPB issued a construction loan factsheet providing an overview on how the TILA-RESPA Integrated Disclosure Rule (TRID) applies to these types of loans. At the outset, the Bureau expressly states TRID applies to most construction loans which are secured, closed-end consumer credit transactions. In contrast, open-end loans or those for a commercial purpose lie...