Regulatory Issues

Regulatory Issues

07.31.17
07.31.17
07.31.17
07.31.17
10.28.15
CMC requests clarification about HID-IG reports that differ from HUD interpretation about HFA down payment assistance programs...Read More
09.04.15
Four trade associations filed a joint letter opposing a proposal to terminate FHA coverage on loans of which claims are filed late....Read More
08.31.15
The FCC released an order in July 2015 that restricts the ability to use "autodialers" -- most phones -- to call wireless numbers without express consent. Foreclosure prevention programs require phone calls....Read More
10.30.14
Joint Letter on HMDA (10-29-14)...Read More
10.29.14
CMC Comment on HMDA (10-29-14)...Read More
10.28.14
CMC Comment on Affordable Housing Goals (2014)...Read More
10.28.14
CMC Comment on Affordable Housing (2004)...Read More
10.28.14
GSE Report Special Supplement -- Unaffordable Housing Goals...Read More
10.28.14
CMC comment letter on 2000 GSE affordable housing goals...Read More
12.10.13
CMC Comment on Interagency Biggert-Waters Proposal...Read More
11.24.13
CFPB servicing guidance September 2013...Read More
11.24.13
CMC QRM comment October 2013...Read More
11.24.13
FHFA final rule on private transfer fees March 2012...Read More
11.24.13
FHFA PACE proposed rule June 2012...Read More
11.24.13
CMC comment on originator compensation October 2012...Read More
11.24.13
CMC letter to regulators on PACE loans July 2010...Read More
11.24.13
FHFA PACE ANPR January 2012...Read More
11.24.13
FHFA withdrew its PACE rulemaking as unnecessary, July 2013...Read More
11.24.13
Joint comment to FHFA on PACE ANPR March 2012...Read More
11.24.13
Joint comment to FHFA on PACE proposed rule Sept. 2012...Read More
11.24.13
CMC letter to FHFA on private transfer fees April 2011...Read More
11.24.13
FHFA private transfer fee proposed guidance August 2010...Read More
11.24.13
FHFA proposed rule on private transfer fees February 2011...Read More
11.24.13
CMC QRM comment August 2011...Read More
11.24.13
Coalition for Sensible Housing Policy on QRM March 2013...Read More
11.24.13
FRB Risk Retention Report October 2010...Read More
11.24.13
QRM proposal April 2011...Read More
11.24.13
QRM reproposal September 2013...Read More
11.24.13
CFPB servicing forms testing August 2012...Read More
11.24.13
CMC comment on servicing rules October 2012...Read More
11.24.13
CMC letter to S&S agencies on Title XIV rules August 2013...Read More
11.24.13
Final Regulation X servicing rule February 2013...Read More
11.24.13
Final Regulation Z servicing rule February 2013...Read More
11.24.13
Proposed Regulation X servicing rule September 2012...Read More
11.24.13
Proposed Regulation Z servicing rule September 2012...Read More
11.24.13
CMC comment on CFPB's HOEPA & KBYO proposals, September 2012...Read More
11.24.13
CFPB's 2012 HOEPA proposed rule...Read More
11.24.13
HUD says it is reviewing disparate impact and the Dodd-Frank Act, 2013...Read More
11.24.13
Final regulation on disparate impact under the Fair Housing Act...Read More
11.24.13
A final HOEPA rule in January 2012...Read More
11.24.13
July 2013 CFPB revisions to servicing rules, QM exemptions, and HPML rules...Read More
11.24.13
CMC-MBA LPI letter to FHFA August 2012...Read More
11.24.13
CMC-MBA LPI letter to FHFA December 2012...Read More
11.24.13
CMC-MBA LPI letter to FHFA June 2012...Read More
11.24.13
CMC comment letter to FHFA on LPI May 2013...Read More
11.24.13
October 2013 revisions to loss mit, originator compensation, and ability-to-repay rules...Read More
11.24.13
CFPB's proposed LO Compensation rule September 2012...Read More
11.24.13
Final LO Compensation rule February 2013...Read More
11.24.13
Joint letter on loan originator compensation July 2012...Read More
11.24.13
Several organizations commented on possible use of eminent domain to take mortgages...Read More
11.24.13
Several organizations commented on possible use of eminent domain to take mortgages...Read More
11.23.13
The CFPB’s Complaint Database Lacks Consumer Privacy Protection...Read More
11.23.13
BUREAU OF CONSUMER FINANCIAL PROTECTION 12 CFR Part 1002 [Docket No. CFPB–2012–0032] RIN 3170–AA26 Disclosure and Delivery Requirements for Copies of Appraisals and Other Written Valuations Under the Equal Credit Opportunity Act (Regulation B) AGENCY: Bureau of Consumer Financial Protection. ACTION: Final rule; official interpretations....Read More
11.20.13
KBYO Final Regulation...Read More
11.11.13
Proposed and Final Rules...Read More
10.30.13
10.03.13
09.26.13
09.26.13
08.30.13
[Docket No. AS12–16] Appraisal Subcommittee; Proposed Policy Statements...Read More
07.24.13
Final Revisions July 24, 2103 Proposed and Final Rules...Read More
06.12.13
Final QM June 2013 Proposed and Final Rules...Read More
05.28.13
Final ASC Policy Statements May 2013...Read More
02.25.13
CMC QM comment on points and fees, originator compensation, and other issues....Read More
02.25.13
The definition of points and fees is critical. While there has been a definition of points and fees for years under the Home Ownership and Equity and Protection Act of 1994 (“HOEPA”),1 it has not been significant because lenders have been unwilling to make HOEPA loans. The Rule will make the definition of points and fees a central issue in mortgage lending because the Rule will create enormous litigation risk for loans that are not qualified mortgage (“QM”) loans within the safe harbor, and because points and fees on QM loans are generally capped at three percent of the loan amount. 1 Home Ownership and Equity Protection Act of 1994, Pub. L. No. 103-325, §§ 151–158, 108 Stat. 2160, 2190-2198 (1994) (codified as amended in scattered sections of the Truth in Lending Act, 15 U.S.C. §§ 1601–1667f). 600 Cameron Street, Alexandria, VA 22314 Telephone: (202) 617-2101 Fax: (202) 318-8587  We would like to observe that the cap on points and fees is not, in any way, related to whether a consumer is able to repay a loan or whether a creditor has sufficiently underwritten a loan. The cap is simply a form of price regulation. The cap will not limit creditors’ ability to recoup their costs, but it will change the method by which they do so, replacing recoupment through points and fees with recoupment through interest rates. The cap will limit consumers’ ability to elect to pay more points in exchange for a lower interest rate. Especially when interest rates are high, this lack of flexibility to choose will harm consumers, and will cause them to pay more over the life of the loan than they would otherwise pay, absent the price cap....Read More
01.31.13
Final QM January, 2013 Proposed and Final Rules...Read More
01.30.13
Part II Bureau of Consumer Financial Protection 12 CFR Part 1026 Ability-to-Repay and Qualified Mortgage Standards under the Truth in Lending Act (Regulation Z); Final Rule...Read More
01.23.13
BUREAU OF CONSUMER FINANCIAL PROTECTION 12 CFR Part 1026 [Docket No. CFPB–2012–0031] RIN 3170–AA11 FEDERAL HOUSING FINANCE AGENCY 12 CFR Part 1222 RIN 2590–AA58 Appraisals for Higher-Priced Mortgage Loans AGENCY: Board of Governors of the Federal Reserve System (Board); Bureau of Consumer Financial Protection (Bureau); Federal Deposit Insurance Corporation (FDIC); Federal Housing Finance Agency (FHFA); National Credit Union Administration (NCUA); and Office of the Comptroller of the Currency, Treasury (OCC). ACTION: Final rule; official staff commentary....Read More
12.21.12
Docket No. R-1394 Regulation Z Interim Final Rule, Valuation Independence...Read More
11.30.12
Proposed Policy Statement Amendments Docket No. AS12-16...Read More
10.15.12
Office of the Executive Secretary Bureau of Consumer Financial Protection Regulation B Proposed Appraisal Rule Docket No. CFPB-2012-0032, RIN 3170-AA26...Read More
10.15.12
AMERICAN FINANCIAL SERVICES ASSOCIATION CONSUMER MORTGAGE COALITION MORTGAGE BANKERS ASSOCIATION...Read More
09.14.12
Appraisal Subcommittee Proposed Policy Statements Docket #AS12-16...Read More
09.10.12
Ms. Monica Jackson Office of the Executive Secretary The Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 Re: Docket No. CFPB-2012-0028 or RIN 3170-AA28...Read More
09.05.12
BUREAU OF CONSUMER FINANCIAL PROTECTION 12 CFR Part 1026 [Docket No. CFPB–2012–0031] RIN 3170–AA11 FEDERAL HOUSING FINANCE AGENCY 12 CFR Part 1222 RIN 2590–AA58 Appraisals for Higher-Risk Mortgage Loans AGENCIES: Board of Governors of the Federal Reserve System (Board); Bureau of Consumer Financial Protection (Bureau); Federal Deposit Insurance Corporation (FDIC); Federal Housing Finance Agency (FHFA); National Credit Union Administration (NCUA); and Office of the Comptroller of the Currency, Treasury (OCC). ACTION: Proposed rule; request for public comment....Read More
09.04.12
Proposed Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the Bureau of Consumer Financial Protection...Read More
08.30.12
Federal Register Comment Extension...Read More
08.23.12
Part II Bureau of Consumer Financial Protection 12 CFR Parts 1024 and 1026 Integrated Mortgage Disclosures Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth In Lending Act (Regulation Z); Proposed Rule...Read More
08.01.12
BUREAU OF CONSUMER FINANCIAL PROTECTION 12 CFR Part 1002 [Docket No. CFPB–2012–0032] RIN 3170–AA26 Equal Credit Opportunity Act (Regulation B) AGENCY: Bureau of Consumer Financial Protection. ACTION: Proposed rule; request for public comment....Read More
07.09.12
The definition of a QM loan is particularly important because it is likely, with rare exception, that lenders will be unwilling to make non-QM loans due to the liability that will attach to them. It is important that creditors and investors be able to distinguish between QM and non-QM loans so they can protect themselves from liability that was designed to attach only to non-QM loans. This necessitates a rule that is very well- defined. The degree of protection from liability and the definition of a QM loan will largely determine the availability of consumer mortgage credit nationwide. Clearly, though, the QM definition should be very broad and cover the majority of borrowers....Read More
04.16.12
April 16, 2012 The Honorable Richard Cordray Director Consumer Financial Protection Bureau 1700 G Street, N.W. Washington, DC 20552 Dear Director Cordray: We read with great interest your interview with Kate Davidson in the March 26, 2012, issue of the American Banker, in which you stated, “We want to make sure we get that as right as we can, so we're trying to be careful.”...Read More
04.16.12
The Honorable Richard Cordray Director Consumer Financial Protection Bureau 1700 G Street, N.W. Washington, DC 20552...Read More
01.27.12
The Honorable Richard Cordray Director Consumer Financial Protection Bureau 1700 G Street, NW Washington DC 20552 January 27, 2012...Read More
12.05.11
Mr. Rajeev Date Special Advisor to the Secretary of the Treasury for the Consumer Financial Protection Bureau 1700 G Street, N.W. Washington, D.C. 20552 Re: Know Before You Owe Prototypes, Round 6...Read More
11.10.11
Rajeev Date Special Advisor to the Secretary of the Treasury for the Consumer Financial Protection Bureau 1700 G Street, N.W. Washington, D.C. 20552 Re: Know Before You Owe Prototypes, Round 5...Read More
11.09.11
Hornbean Disclosure Form...Read More
11.08.11
Ironwood Disclosure Form...Read More
10.31.11
Rajeev Date Special Advisor to the Secretary of the Treasury for the Consumer Financial Protection Bureau 1700 G Street, N.W. Washington, D.C. 20552 Re: Know Before You Owe Prototypes, Round 5...Read More
10.21.11
Pinyon Bank...Read More
10.18.11
Additional page for Federal Disclosures....Read More
10.18.11
Jasmine Home Loans...Read More
10.18.11
Nandina Home Loans...Read More
08.08.11
Mr. Rajeev Date Special Advisor to the Secretary of the Treasury for the Consumer Financial Protection Bureau 1801 L Street, N.W. Washington, D.C. 20036 Re: Know Before You Owe Prototypes, Round 3...Read More
07.22.11
Qualified Mortgage Proposed Rule Docket No. R-1417 RIN No. 7100-AD75...Read More
07.12.11
Professor Elizabeth Warren Special Advisor to the Secretary of the Treasury for the Consumer Financial Protection Bureau 1801 L Street, N.W. Washington, D.C. 20036 Re: Know Before You Owe Prototypes, Round 2...Read More
06.28.11
Professor Elizabeth Warren Special Advisor to the Secretary of the Treasury for the Consumer Financial Protection Bureau 1801 L Street, N.W. Washington, D.C. 20036 Re: Know Before You Owe Prototypes...Read More
06.28.11
Pecan Bank...Read More
06.28.11
Dogwood Credit Union...Read More
06.28.11
Redbud Credit Union...Read More
06.28.11
Ficus Bank...Read More
11.10.10
November 10, 2010 The Honorable Timothy F. Geithner Secretary U.S. Department of the Treasury 1500 Pennsylvania Avenue, NW Washington, DC 20220 The Honorable Shaun Donovan Secretary U.S. Department of Housing and Urban Development 451 Seventh Street, SW Washington, DC 20410 The Honorable Ben Bernanke Chairman Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue, NW Washington, DC 20551 Dear Secretary Geithner, Secretary Donovan and Chairman Bernanke: The undersigned trade associations, representing the real estate finance industry, appreciate the Board’s and HUD’s efforts to improve disclosures to mortgage borrowers under the Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA). At this point, however, Special Advisor to the President Elizabeth Warren and Treasury staff have begun discussions internally and with stakeholders to combine the two disclosures into a single, integrated disclosure, and we understand that effort will be a first priority of the new Bureau of Consumer Financial Protection (Bureau)....Read More
10.28.10
FEDERAL RESERVE SYSTEM 12 CFR Part 226 Regulation Z; Docket No. R–1394 RIN AD–7100–56 Truth in Lending AGENCY: Board of Governors of the Federal Reserve System. ACTION: Interim final rule; request for public comment....Read More
10.01.08
Policy Statements Regarding State Certification and Licensing of Real Estate Appraisers...Read More