The ""Mortgage Bankers Association"":http://www.mbaa.org/default.htm (MBA) released to the public ""a letter"":http://www.mortgagebankers.org/files/News/InternalResource/82310_MBACommentLetterofServicingStandards.pdf urging the ""Consumer Financial Protection Bureau"":http://www.consumerfinance.gov/ (CFPB) to avoid proposals that may lead to ""unforeseen and unintended consequences"" harmful to the industry.[IMAGE]
In a letter published on the association's site, MBA president and CEO David Stevens urges CFPB to consider both borrower needs and servicer limitations when designing mortgage industry regulations.
Specifically, Stevens asks CFPB to limit its rulemaking to the mandates required by the Dodd-Frank Act and to use its exemption authority to remove ""unduly burdensome"" requirements. In the same vein, he expresses MBA's concern about a proposed rule that allows borrowers to sue if a servicer fails to observe an item not outlined in Dodd-Frank or other congressionally authorized legislation.
He also recommends that servicers be given two years to implement CFPB's rules once they are finalized, while small servicers (defined by Stevens as companies that service $10 billion or less in residential mortgage loans) should receive an additional six months.
The 97-page letter goes on to detail specific concerns and recommendations for proposed regulations.
MBA isn't alone in its efforts to appeal to the bureau. In its ""own letter"":http://www.aba.com/Solutions/Mortgage/Documents/ABACommentstoCFPBon2012TILARegZMortgageServicing1092012.pdf to CFPB sent on the same day, the ""American Bankers Association"":http://www.aba.com/Pages/default.aspx expresses many of the same worries about the current proposed rules.
CFPB, established with the passage of the Dodd-Frank Act, accepts input from the public at large on proposed rules. With many lenders and banking institutions struggling to comply with looming requirements, organizations of all sizes are weighing in on the future of mortgage regulation.
In his letter, Robert Davis-EVP of mortgage markets, financial management, and public policy for ABA-gives his view on what's at stake.
""The CFPB is shaping the U.S. mortgage market of the future. This is an important undertaking that carries significant responsibility,"" Davis writes. ""The CFPB's rulemakings may affect the availability and cost of mortgage-related products and services for years to come.""