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 18, 2013CFPB Issues Final Rules on Mortgage Servicing On Thursday, January 17, 2013, the CFPB issued its final rules on mortgage servicing, which are scheduled to take effect on January 10, 2014. The servicing rules were published in two notices amending Regulation Z, which implements the Truth in Lending Act, and Regulation X, which implements the Real Estate Settlement Procedures Act. CBA will hold an...
January 18, 2013CFPB Issues Mortgage Servicing Rules Nearly 300 members dialed joined CBA’s call on Monday, January 14, 2013, to discuss the impact of QM and to hear from K&L Gates and the CBA Advocacy team. With regard to QM, Director Cordray told me the 3% cap on mortgage broker compensation is a work in progress. While we appreciate the CFPB's efforts to date, we still have some concerns, outlined in our...
January 16, 2013Washington, D.C. (January 16, 2013) – CBA is pleased the new rule establishes a broad definition of a “qualified mortgage” and lenders will have “safe harbor” protection from liability for most of these loans. This will prevent an unnecessary restriction in mortgage credit to consumers, while still ensuring that creditors consider consumers’ ability to repay. We appreciate the CFPB working with...
CBA Joint Trade Comment Letter on the Bureau’s proposal to temporarily delay the effective date of the remittance rules