CHLA Submits Recommendations To CFPB To Implement President’s Executive Order On Mortgages

The Community Home Lenders of America (CHLA) today submitted formal comments in response to the CFPB’s “Request for Information regarding Promoting Access to Mortgage Credit,” in order to implement the President’s Executive Order on Mortgages.

The CHLA letter includes detailed recommendations, calling for:

1. Tiered Regulation of Smaller IMBs, per the Dodd-Frank statute.

2. Limiting LO Comp restrictions to compensation between firms.

3. TRID Reforms – Permitting consumers to waive TRID waiting periods for a bona fide financial emergency and revised TRID tolerances for government-imposed and 3rd party fees

4. Targeted Revisions to QM Points and Fees Calculations, to boost first-time homebuyers.

“[CHLA reccommendations] advance the objectives identified in Executive Order 14393 and the Bureau’s Request for Information by lowering origination costs, expanding lender participation, promoting competition, and improving access to sustainable mortgage credit, without weakening core consumer protections,” the CHLA letter said.

CHLA is renewing its call for a CFPB supervisory exemption for smaller IMBs comparable to the one that exists for smaller banks.  The Dodd-Frank statutory requirement for tiered regulation by loan volume, firm size, product risk, and extent of state regulation  has never been explicitly implemented for IMBs (non-bank mortgage lenders).

CHLA also renewed its call for reform of LO Comp, by limiting its application only to compensation between  firms, as recommended in last year’s CHLA LO Comp White Paper.

Finally, the CHLA letter included appendices with detailed recommendations to revise TRID and QM.