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 21, 2014
    GAO Finds Deficiencies with Internal Controls at CFPB On Tuesday, November 18, 2014, the Government Accountability Office (GAO) released their annual audit report conducted on the CFPB for the year ending September 30, 2014. The report found the agency continues to struggle with internal controls, among other issues. Specifically, GAO found the CFPB did not have effective procedures in place to...
  • November 10, 2014
    Re: File Error Rate Clarification for the Request for Comment on Proposed Amendments to Regulation C, Implementing the Home Mortgage Disclosure Act, Docket No. CFPB-2014-0019 Dear Ms. Jackson: The Consumer Bankers Association (“CBA”) and American Bankers Association (“ABA”) would like to clarify the “File Error Rate” section of our previously submitted joint trade response (“Joint Letter”) to the...
  • October 29, 2014
    Ms. Monica Jackson Office of the Executive Secretary
 Consumer Financial Protection Bureau 1700 G Street NW Washington, D.C. 20552 Re: Request for Comment on Proposed Amendments to Regulation C to Implement Amendments to Home Mortgage Disclosure Act, Docket No. CFPB-2014-0019 Dear Ms. Jackson: The Consumer Bankers Association (“CBA”), [1] American Bankers Association (“ABA”), [2] Financial...
  • October 24, 2014
    CFPB Proposes a Language Access Plan On Thursday, October 23, 2014, the CFPB announced a proposed Language Access Plan , which seeks to expand the availability of financial information to those members of the public who have difficulty with the English language. According to the U.S. Census Bureau, about 24 million people in the United States say they don't speak English "very well." The Language...
  • October 17, 2014
    White House Announces Action on Data Security and Consumer Financial Transactions On Friday, October 17, 2014, the President signed an Executive Order directing the government to lead by example in securing transactions and sensitive data. The BuySecure Initiative is intended to provide consumers with more tools to secure their financial future by assisting victims of identity theft, improving...
  • October 10, 2014
    CFPB Holds Forum on Checking Account Access On Wednesday, October 8, 2014, the CFPB held a forum on access to checking accounts. The event featured remarks from CFPB Director Richard Cordray, as well as presentations from consumer groups, federal and local government officials, and industry representatives. The CFPB's stated goal of the forum was to learn more about how the checking account...
  • October 3, 2014
    CFPB Issues Report on Loans for Manufactured Housing On Tuesday, September 30, 2014, the CFPB issued a report on the manufactured housing market, owner demographic, and loan terms. The Bureau found the median age of manufactured-home owners to be 53, with most living in rural areas and possessing a low net worth. Borrowers of manufactured home loans pay a higher interest rate than borrowers whose...

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