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.
- November 20, 2019On Wednesday, November 20, 2019, the Bureau released a Request for Information (RFI) asking for feedback on Integrated Mortgage Disclosures Under the Real Estate Procedures Act and the Truth In Lending Act, as well as certain amendments in accordance with Section 1022(d) of Dodd-Frank. Under the RFI, the Bureau asks for comment on its plan to asses the rule as well as recommendations that may be...October 15, 2019Comment Intake Bureau of Consumer Financial Protection 1700 G Street NW Washington, DC 20552 Re: Docket No. CFPB-2019-0020; Home Mortgage Disclosure (Regulation C) Data Points and Coverage Ladies and Gentlemen: The American Bankers Association, Bank Policy Institute, Consumer Bankers Association, Housing Policy Council, and Mortgage Bankers Association (the “Associations”), on behalf of our...October 10, 2019On Thursday, October 10, 2019, the Bureau issued a rule which finalizes certain aspects of its May 2019 Notice of Proposed Rulemaking under the Home Mortgage Disclosure Act (HMDA). It extends for two years the current temporary threshold for collecting and reporting data about open-end lines of credit under HMDA. The rule also clarifies partial exemptions from certain HMDA requirements which...October 7, 2019Today’s customers want a bank that offers services tailored to their individual needs. Retail banks are now under pressure to provide personalized banking products, lending and savings recommendations, and other customized experiences to each individual account holder. How do you solve pricing end to end across your organization, so you consistently get the right offers to the customers you need...September 30, 2019Two things generally happen when your customers start their home buying process. They are overwhelmed with the amount of choices as they look for a lender and then again are overwhelmed by the complexity of your loan application process. True customer-centricity alleviates many of the stresses ailing your customers by keeping your institution top of mind before they even start down the path to...September 25, 2019Marketplace lenders are disrupting the lending industry by making the process easier, faster, and more customer-centric. In response, traditional banks are implementing new strategies that are more focused on the customer and that engage the customer throughout their journey with the bank. In this guide, you will: Hear from US Consumers who have opened a HELOC in the past 12 months Develop...August 14, 2019 - 2:00PMPastJune 11, 2019The new accounting standard, Current Expected Credit Loss (CECL), may require significant changes to the data a lender maintains and analyzes, and involves a deeper level of modeling, analysis and reporting than previously required. This eBook provides actionable insights and tips to help you gain confidence in your CECL plan and develop a winning strategy. To download the Ebook or learn more...June 5, 2019On Wednesday, June 5, 2019, the CFPB announced a settlement with Freedom Mortgage Corporation for violations of HMDA and Regulation C. Freedom is one of the nation’s largest reporters, and reported inaccurate race, ethnicity, and sex information and that much of Freedom’s loan officers’ recording of this incorrect information was intentional. For example, certain loan officers were told by...
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Joint Comment Letter re Disparate Impact Letter