Mortgage & Home Equity
Please read CBA’s summary of the proposed TILA-RESPA Rule. Click here to read part one of the summary; click here to read part two of the summary.
Mortgage and home equity products have received increased regulatory and legislative scrutiny over the over the past few years. With the collapse of the mortgage markets in late 2008, federal regulators and Capitol Hill have made mortgage related products a primary issue. The bank industry has also witnessed increased scrutiny from the states, both individually and collectively and the Consumer Financial Protection Bureau (CFPB) promises to greatly alter the way financial institutions manage their mortgage and home equity products.
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. Through its Home Equity Committee, CBA has expanded its scope to include all mortgage related issues and will be focused primarily the efforts of the CFPB to regulate in this space.
Issues CBA will be focused on include:
- TILA-RESPA Reform—combining and streamlining disclosure requirements.
- Ability to Pay—The CFPB’s implementation of the Dodd-Frank Act provisions, including the “Qualified Mortgage”.
- Dodd-Frank Title 14 Rulemaking—Mortgage changes that go into effect on January 2013 will call regulations from the CFPB.