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 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