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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.
- November 29, 2017On Wednesday, November 29, 2017, the Fed, OCC, and FDIC issued a final rule revising regulations implementing the Community Reinvestment Act (CRA). The final rule amended the definitions of “home mortgage loan” and “consumer loan” to align with changes to CFPB Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). The final rule also amended CRA public file content requirements...November 28, 2017On Tuesday, November 28, 2017, the Federal Reserve (Fed) issued a consent order against Peoples Bank of Lawrence, KS, claiming the bank engaged in deceptive residential mortgage origination practices which violated the Federal Trade Commission Act (FTCA). According to the Fed, Peoples told borrowers they were paying a certain amount for discount points that would lower the borrower’s interest...November 24, 2017November 24, 2017 Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Disclosure of Loan-Level HMDA Data; Docket No. CFPB-2017-0025 Dear Ms. Jackson, We appreciate the opportunity to provide comments on the Consumer Financial Protection Bureau’s (CFPB or Bureau) proposed policy guidance, Disclosure of Loan-Level HMDA...November 24, 2017Washington, D.C. – The Consumer Bankers Association (CBA), along with four other trades, today urged the Consumer Financial Protection Bureau (CFPB) to alter the way the agency reports loan-level HMDA data to prevent the public release of individual consumers’ HMDA data and unnecessary exposure to increased privacy risks, identity theft and fraud. In order to protect consumers from harm, the...November 20, 2017On Monday, November 20, 2017, the Federal Reserve, FDIC and OCC announced amendments to their respective Community Reinvestment Act (CRA) regulations. The changes conform to conforming to amendments made by the CFPB to Regulation C, implementing the Home Mortgage Disclosure Act (HMDA). In addition, the final rule contains technical corrections and removes obsolete references to the Neighborhood...November 20, 2017On Monday, November 20, 2017, the CFPB, Federal Reserve and OCC announced an increase to the threshold for exempting loans from special appraisal requirements for higher-priced mortgage loans. During 2018, the threshold will increase from $25,500 to $26,000 effective January 1, 2018, according to the Federal Register . The threshold change was based on the annual percentage increase in the...October 30, 2017On Monday, October, 30, 2017, the CFPB launched a mortgage performance trends tool tracking nationwide delinquency rates, and showing mortgage delinquency rates are at their lowest point since the financial crisis. The tool measures the delinquency rates in two general categories: Borrowers who are 30-89 days behind on mortgage payments, meaning they have missed one or two payments; and Serious...October 20, 2017October 20, 2017 Legislative and Regulatory Activities Division Office of the Comptroller of the Currency 400 7 th St. SW, Suite 3E-218 Washington, DC 20219 Via electronic submission Re: OCC Community Reinvestment Act Regulations (Docket ID OCC-2017-0008) To Whom It May Concern, The Consumer Bankers Association (“CBA”)  appreciates the opportunity to respond to the Office of the Comptroller of...October 17, 2017On Tuesday, October 17, 2017, the OCC issued a bulletin to inform national banks, federal savings associations, and insured federal branches and agencies of foreign banks about key fields examiners will typically use to validate the accuracy and reliability of home mortgage loan data collected beginning in 2018 pursuant to the Home Mortgage Disclosure Act (HMDA) rule issued October 15, 2015. The...October 17, 2017On Tuesday, October 17, 2017, the OCC, the Board of Governors of the Federal Reserve, the FDIC, and the National Credit Union Administration issued a press release exempting real estate-related transactions from appraisal requirements in major disaster areas as declared by President Trump. The exemptions will be in effect for a three-year period from the date of declaration. Included are parts of...