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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.
- January 9, 2015CFPB Releases Report on MLA On Monday, December 29, 2014, the CFPB released a report claiming loopholes in the current Military Lending Act (MLA) rules cause servicemembers to incur extra costs. The report asserts loopholes have enabled companies to offer pricey loans to military families by avoiding the 36 percent rate cap and other credit protections specific to the military. This cap includes...
- November 21, 2014GAO 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, 2014Re: 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...
- November 5, 2014November 3, 2014November 3, 2014October 29, 2014Ms. 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”),  American Bankers Association (“ABA”),  Financial...October 24, 2014CFPB 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, 2014White 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, 2014CFPB 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...