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.
  • September 18, 2015
    CFPB Develops New Tools for Consumers Shopping for a Mortgage On Thursday, September 17, 2015, the CFPB released new online tools under its "Know Before You Owe" initiative to help consumers shopping for a mortgage. The new tools are designed to help consumers decide if they are ready to purchase a home, how to get a mortgage, obtain an offer, and close the transaction. "Our new mortgage forms...
  • September 8, 2015
    September 8, 2015 By electronic delivery to: Re: FFIEC Requested Action on TRID Lady and Gentlemen: The undersigned trade associations write with great urgency regarding implementation and examination issues stemming from the TILA/RESPA Integrated Disclosure (TRID) rule effective on October 3, 2015. In official issuances and communications to Congress, the Consumer Financial Protection Bureau (...
  • September 3, 2015
    Following the launch of a complaint database managed by the Consumer Financial Protection Bureau (CFPB), mortgage industry players are seeking some changes to the way complaints are collected and displayed to the public. The complaint database has been met with much opposition among businesses and political leaders since its inception, most recently for the way in which it processes and displays...
  • September 2, 2015
    The mortgage finance industry is still not happy with theConsumer Financial Protection Bureau and its consumer complaint narrative database, which publishes unvetted and unverified anonymous complaints against specific companies. The database published by the CFPB contains complaints from consumers about companies, and the only verification is that there was a transaction between the complaining...
  • August 14, 2015
    Agencies Take Action Against Citizens On Wednesday, August 12, 2015, the CFPB, FDIC and OCC entered into a consent order with Citizens Bank for allegedly failing to credit consumers the full amounts of their deposited funds. The agencies claim, between January 1, 2008 and November 30, 2013, the bank kept money from deposit discrepancies when receipts did not match the actual money transferred...
  • August 7, 2015
    Another Constitutionality Challenge Filed Against the CFPB PHH Corporation on Friday, June 26, 2015 filed a Motion for Stay Pending Judicial Review with the D.C. Circuit Court of Appeals (Court) seeking to stay a final action of the CFPB scheduled to take effect on Wednesday, August 5, 2015. On Monday, August 3, 2015, the Court granted PHH's motion, finding the company had "satisfied the...
  • August 7, 2015
    CFPB and the Question of Constitutionality "The constitutionality of the CFPB's structure is now on track for its first review by a federal appeals court. This is going to be interesting," wrote Alison Frankel for Reuters on Tuesday, August 4, 2015. The day before, the motions panel of the District of Columbia U.S. Circuit Court of Appeals granted PHH Corporation's motion, finding the company had...
  • July 31, 2015
    Inspector General Study on CFPB Complaint Portal Finds Inadequacies On Thursday, July 23, 2015, the Office of the Inspector General (OIG) for the CFPB and Federal Reserve Board finalized the Security Control Review of the CFPB’s Data Team Complaint Database. The OIG it will not release the full report due to the sensitive nature of the information, but instead published a summary of conclusions...
  • July 27, 2015
    July 27, 2015 The Honorable Jeb Hensarling The Honorable Maxine Waters Chairman Ranking Member House Financial Services Committee House Financial Services Committee 2149 Rayburn House Office Building B301C Rayburn House Office Building Washington, D.C. 20515 Washington, D.C. 20515 Dear Chairman Hensarling and Ranking Member Waters: The undersigned organizations urge you to pass H.R. 3192, the...
  • July 22, 2015
    The consumer protection body, which regulates consumer lending, has published annual complaint reports since its inception four years ago. Previously, Anotakes was the state banking commissioner in Massachusetts. “They’re basically in the shaming of banks business by providing what I call a “David Letterman Top 10 List” of complaints”, says Richard Hunt, president of the Consumer Bankers...

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