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OCCRulemakingOCC-2013-0010

Credit Risk Retention

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closed 4654d ago
Mortgage Bankers Association filings
16

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Mortgage Bankers Association filed 16 comments on this docket between Oct 25, 2013 and Nov 12, 2013. 64 other organizations filed here. The comment window closed 4654d ago.

What Mortgage Bankers Association filed (16)

Nov 12, 2013· Wisconsin Mortgage Bankers Association· OCC-2013-0010-0195

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Nov 1, 2013· Ohio Mortgage Bankers Association· OCC-2013-0010-0086

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Nov 1, 2013· Mortgage Bankers Association of Florida· OCC-2013-0010-0084

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Nov 1, 2013· Mortgage Bankers Association of Arkansas· OCC-2013-0010-0083

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Nov 1, 2013· Vermont Mortgage Bankers Association· OCC-2013-0010-0128

See attached file(s) Vermont Mortgage Bankers Assn. 12 N Main St. St. Albans, VT 05478 October 30, 2013 Re: Credit Risk Retention Re-Proposal Dear Sirs and Madam: On August 28, 2013, the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (the Board), Federal Deposit Insurance Corporation (FDIC), Securities and Exchange Commission (SEC), Federal Housing Finance Agency (FHFA), and the Department of Housing and Urban Development (HUD) (collectively, the Agencies) jointly issued a notice of proposed rulemaking (the Proposal) to implement § 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank or the Act) regarding credit risk retention including the Qualified Residential Mortgage (QRM). The Proposal is a re-proposal of a proposed rule issued in the spring of 2011 on this subject. After intense push-back, the Agencies re-proposed the rule in 2013. The 2013 re-proposal represents an improvement from the original because it aligns the QRM definition with the QM standard finalized earlier this year by the CFPB. •As the data demonstrate, the QM definition sets forth a rigorous standard for sustainable mortgage lending which result in borrowers' ability to repay and significantly lowers delinquencies and defaults; •Aligning the QRM and QM definitions will allow a greater number of borrowers to benefit from lower mortgage costs resulting from greater access to the private investor market, as well as safer and more sustainable loans; •Aligning the QRM definition with the QM standard will streamline the regulatory burden on an industry where the costs of regulation have become a great concern; and •The respective legislative intent of QRM and QM are well satisfied by the Agencies adoption of the same definition. Despite the improvements, we have several concerns with the re-proposal. In particular, we are deeply concerned with the Alternative QM-Plus Approach. This Alternative would require a loan qualifying for the QRM exemption to have a 30% down payment and subject the borrower to onerous credit history requirements. The following are just some of the arguments against the Alternative: •The Alternative's inclusion of a down payment requirement is inconsistent with the legislative intent; •The Alternative restricts too many consumers' access to the most affordable credit available; •The Alternative would exclude a greater number of minority borrowers from the most competitive loans than the Preferred Approach; •The Alternative is unnecessary because the investor market can easily ascertain and price transparent credit attributes like loan-to-value ratio (LTV); •The Alternative will raise costs to borrowers. Consumers who do not qualify for QRM will pay higher prices for ever-scarcer private label credit; and •The Alternative of a more restrictive QRM will increase Government and agency involvement in the mortgage market when the Government's footprint and risk should be reduced. Sincerely, Vermont Mortgage Bankers Association 866-680-8622 Vermontmba.org info@vermontmba.org

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Nov 1, 2013· Tennessee Mortgage Bankers Association· OCC-2013-0010-0117

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Nov 1, 2013· Mortgage Bankers Association of Mississippi· OCC-2013-0010-0106

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Nov 1, 2013· Rhode Island Mortgage Bankers Association· OCC-2013-0010-0089

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Nov 1, 2013· Mortgage Bankers Association of Georgia· OCC-2013-0010-0145

Please find our comments regarding the attached. Thank you.

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Nov 1, 2013· Maryland Mortgage Bankers Association· OCC-2013-0010-0105

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Nov 1, 2013· Mortgage Bankers Association of Metropolitan Washington· OCC-2013-0010-0085

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Nov 1, 2013· Texas Mortgage Bankers Association· OCC-2013-0010-0118

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Oct 30, 2013· Mortgage Bankers Association of Alabama, Inc.· OCC-2013-0010-0055

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Oct 30, 2013· California Mortgage Bankers Association· OCC-2013-0010-0065

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Oct 28, 2013· Massachusetts Mortgage Bankers Association· OCC-2013-0010-0046

See attached file(s) Thank you for the opportunity to provide you with our comments. The Massachusetts Mortgage Bankers Association (MMBA) is the Commonwealth's trade association representing the real estate finance industry. The MMBA promotes fair and ethical lending practices and promotes excellence and integrity among real estate finance professionals through a wide range of educational programs, advocacy and industry-wide publication. Its membership of approximately 250 companies includes all elements of real estate finance: mortgage companies, mortgage brokers, commercial banks, thrifts, insurance companies, appraisers, etc. and others in the mortgage lending field.

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Abstract

The OCC, Board, FDIC, Commission, FHFA, and HUD (the agencies) are seeking comment on a joint proposed rule (the proposed rule, or the proposal) to revise the proposed rule the agencies published in the Federal Register on April 29, 2011, and to implement the credit risk retention requirements of section 15G of the Securities Exchange Act of 1934 (15. U.S.C. 78o-11), as added by section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). Section 15G generally requires the securitizer of asset-backed securities to retain not less than 5 percent of the credit risk of the assets collateralizing the asset-backed securities. Section 15G includes a variety of exemptions from these requirements, including an exemption for asset-backed securities that are collateralized exclusively by residential mortgages that qualify as ``qualified residential mortgages,'' as such term is defined by the agencies by rule.

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Co-filers (64)

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