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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.
- July 31, 2017July 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 28, 2017A 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, 2017On 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, 2017On 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...June 21, 2017June 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, 2017On 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 13, 2017The U.S. Treasury Secretary Steven Mnuchin unveiled the much-anticipated report on the department's assessment of the financial market as ordered by President Donald Trump earlier this year. The report details potential executive actions and regulatory changes that can be immediately undertaken to provide much-needed relief, according to the Treasury. Though, to be sure, the timeline of...June 7, 2017On Wednesday, June 7, 2017, the CFPB took action against mortgage servicer Fay Servicing for failing to provide mortgage borrowers with the protections against foreclosure required by law. The Bureau found Fay violated the Bureau’s servicing rules by keeping borrowers in the dark about critical information regarding the process of applying for foreclosure relief. The Bureau also found instances...May 31, 2017On Wednesday, May 31, 2017, the CFPB released its monthly complaint report highlighting complaints submitted by older consumers. The snapshot shows older consumers frequently report servicing problems with reverse mortgages, difficulties recovering money after financial scams, confusion around deferred interest credit cards, and charges for unauthorized add-on products. The snapshot provides an...May 25, 2017May 25, 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: Technical Corrections and Clarifying Amendments to the Home Mortgage Disclosure Act (Regulation C) October 2015 Final Rule; Docket No. CFPB-2017-0010 Dear Ms. Jackson, The Consumer Bankers Association (“CBA”)  and the...