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.
  • September 17, 2017
    If you’ve got a problem with your bank’s overdraft fees, you should say something. That’s what U.S. Sen. Cory Booker recently did. In letters to 13 bank CEOs , the New Jersey Democrat asked for details about their overdraft practices, efforts to convince customers to join overdraft protection programs and reliance on overdraft fees as a source of income. One of his key concerns: Only a small...
  • August 24, 2017
    On Thursday, August 24, 2017, issued a report warning older consumers about taking out a reverse mortgage loan in order to bridge the gap in income while delaying Social Security benefits until a later age. The CFPB report found, in general, the costs and risks of taking out a reverse mortgage exceed the cumulative increase in Social Security lifetime benefits that homeowners would receive by...
  • August 24, 2017
    On Thursday, August 24, 2017, the CFPB issued a rule amending the 2015 updates to the HMDA rule. The Bureau has temporarily changed reporting requirements for banks and credit unions that issue home-equity lines of credit, and clarified the information that financial institutions are required to collect and report about their mortgage lending. Key points of the update are as follows: Reporting...
  • July 31, 2017
    July 31, 2017 Ms. Monica Jackson Office of the Executive Secretary Bureau of Consumer Financial Protection 1700 G Street, NW Washington, DC 20552 Via electronic submission Re: Response of the Consumer Bankers Association to the Request for Information Regarding Ability-to-Repay/Qualified Mortgage Rule Assessment (Docket No. CFPB-2017-0014) Dear Ms. Jackson, The Consumer Bankers Association (“CBA...
  • July 31, 2017
    July 31, 2017 The Honorable Melvin L. Watt Director Federal Housing Finance Agency 400 7th Street, SW Washington, DC 20219 cc: Office of Housing and Regulatory Policy RE: Improving Language Access in Mortgage Lending and Servicing Dear Director Watt: The American Bankers Association (ABA), the Consumer Bankers Association (CBA), the Housing Policy Council of the Financial Services Roundtable (HPC...
  • July 28, 2017
    A m erican Bankers Association Consumer Bankers Association Consumer Mortgage Coalition Ho using Policy Council of The Financial Services Roundtable Mortgage Bankers Association July 28, 2017 Richard Cordray, Director Consumer Financial Protection Bureau 1275 First St, NE Washington, DC 20002 RE: Request for Delayed Implementation of the Home Mortgage Disclosure (Regulation C) October 2015 Final...
  • July 19, 2017
    On Wednesday, July 19, 2017, the FDIC, Fed, and OCC jointly issued a notice of proposed rulemaking titled: “Real Estate Appraisals” to be published in the Federal Register for a 60-day comment period. The Appraisal Rule aims to increase the current appraisal threshold for commercial real estate transactions from $250,000 to $400,000. The Appraisal Rule also aims to address comments received...
  • June 21, 2017
    June 21, 2017 The Honorable James Mattis Secretary of Defense 1000 Defense Pentagon Washington, DC 20301-1000 Dear Mr. Secretary, As we approach the first anniversary of the implementation of the Department of Defense’s amended Military Lending Act (MLA) Regulation, the Financial Trade Associations – the American Bankers Association, the American Financial Services Association, the Association of...
  • June 21, 2017
    On Friday, June 21, 2017, CBA and other financial trades submitted a letter to the U.S. Department of Defense (DoD) recommending changes to the Military Lending Act (MLA). Specifically, the letter requests the DoD: Clarify the exemption for purchase money loans (including vehicle purchase money loans) applies unless the borrower is receiving cash from the proceeds of the loan. Thus, purchase...
  • June 21, 2017
    On Wednesday, June 21, 2017, the Board of Governors of the FED, FDIC, and OCC announced the availability of the 2017 list of distressed or underserved nonmetropolitan middle-income geographies, where revitalization or stabilization activities are eligible to receive CRA consideration under the community development definition. Distressed nonmetropolitan middle-income geographies and underserved...

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