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.
  • October 30, 2013
    Dear Sirs or Madams: The Consumer Bankers Association (CBA) appreciates the opportunity to comment on the credit risk retention proposal issued on August 28, 2013 by the Board of Governors of the Federal Reserve System, the Department of Housing and Urban Development, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, and the Securities and Exchange Commission (the “...
  • October 30, 2013
    Dear Commissioner Galante: The undersigned Associations are grateful for the important work of the Department of Housing and Urban Development (HUD) in developing a proposed rule to define a Qualified Mortgage (QM) for purposes of the Federal Housing Administration (FHA) Insured and Guaranteed Single Family Mortgage Program. Absent such a definition, we believe many consumers would be needlessly...
  • October 25, 2013
    Roundtable Meetings CBA hosted 2 ½ days of exclusive Executive Roundtable sessions this week. We had an impressive and diverse group representing 16 of our member banks and 1 prospective member. Thank you to our guest speakers: Reps. Blaine Luetkemeyer (R-MO), and Patrick Murphy (D-FL); Jaret Seiberg, Guggenheim Partners; and Bart Shapiro, Offit Kurman Law Firm. None of this could have been...
  • October 25, 2013
    CFPB Issues Remittance Exam Procedures On Tuesday, October 22, 2013, the CFPB announced the publication of exam procedures and a small entity guide for the remittance rules, which take effect on October 28, 2013. The CFPB also announced the launch of an eRegulations tool, a web-based version of the Bureau’s rules. Regulation E, including the remittance rule, is the first regulation to be included...
  • October 22, 2013
    Washington, D.C. (October 22, 2013) – Richard Hunt, president and CEO of the Consumer Bankers Association, issued the following response after the Federal Reserve, CFPB, FDIC, OCC, and NCUA issued an interagency statement on fair lending compliance with the Ability-to-Repay/Qualified Mortgage (QM) rule: “Today’s joint statement is a welcome starting point from industry regulators. Consumers come...
  • October 18, 2013
    CFPB Issues Bulletin, Interim Rules to Clarify Mortgage Servicing Requirements On Tuesday, October 15, 2013, the CFPB released a bulletin and interim final rule providing additional guidance on the mortgage servicing rules issued in January. The guidance addresses several issues, such as communications with family members of deceased barrowers, contact with delinquent borrowers, and the treatment...
  • October 11, 2013
    Enforcement Attorneys Will Not be Present at CFPB Examinations On Wednesday, October 9, 2013, The Wall Street Journal reported that the Consumer Financial Protection Bureau (CFPB) indicated it is changing its policy regarding enforcement attorney involvement in the examination process. Beginning November 1, 2013, CFPB enforcement attorneys will no longer be present at examinations. Industry...
  • October 4, 2013
    CFPB Releases Second Annual CARD Act Report On Wednesday, October 2, 2013, the CFPB issued a report on the effects the Credit Card Accountability Responsibility and Disclosure (CARD) Act has had on the consumer credit card market. The report details how the Act has reduced penalty fees and made the cost of credit cards clearer to consumers. The report found the total cost of credit declined by...

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