Comment Letters

July 27, 2010 | Filed under: Mortgage, Real Estate & Housing

We are pleased with the overall proposal, and appreciate the attention given to comments we submitted earlier in 2010 on the Advance Notice of Proposed Rulemaking. The importance of the Enterprises’ role in meeting consumers’ need for affordable and sustainable mortgage credit is greater today than in recent years. The mortgage crisis has highlighted the dangers of unregulated capital market participation in the mortgage system, and the risks to which consumers can be exposed when unsustainable mortgage products are allowed to proliferate.

May 11, 2010 | Filed under: Mortgage, Real Estate & Housing

The Corker-Gregg-Isakson (#3834) amendment replaces the risk retention provisions of S. 3217, Title VII, Subtitle D, (b) Credit Risk Retention with a study on the feasibility of risk retention requirements for financial institutions and implements residential mortgage underwriting standards that include a mandatory 5% down payment for all mortgages. This Amendment would leave in place the misaligned incentives and bad business practices that led us into this mortgage crisis. The McCain-Shelby-Gregg (#3839) amendment would radically reshape the U.S. housing finance system by putting arbitrary timetables into place for the dissolution of Fannie Mae and Freddie Mac, without suggesting any form of substitute to insure continued access to affordable long term mortgage credit for consumers, jeopardizing mortgage liquidity in both the near and long term.

March 26, 2010 | Filed under: Mortgage, Real Estate & Housing

 We are legal services organizations, participants in the Institute for Foreclosure Legal Assistance (IFLA), who represent low and moderate income homeowners around the country facing foreclosure. In our daily work on housing and foreclosure-prevention issues, we see first hand how HAMP is flawed. We would like the opportunity to meet with you and your colleagues at Treasury to discuss the situation of homeowners on the ground and the ways the HAMP program could be improved to meet the needs of communities.

October 19, 2009 | Filed under: Mortgage, Real Estate & Housing

The undersigned consumer, community, labor and civil rights organizations write to request a meeting with you to discuss the Administration’s efforts to prevent mortgage foreclosures. Our organizations are on the front lines of this crisis, and have a deep concern about its impact: our members are directly affected by this problem, and many of us provide counseling and other forms of assistance to homeowners who are in danger of losing their homes.

February 9, 2009 | Filed under: Mortgage, Real Estate & Housing

NACA and other consumer groups submit comments to the Board of Governors of the Federal Reserve System regarding Docket No. R-1340.

February 6, 2009 | Filed under: Mortgage, Real Estate & Housing

The undersigned civil rights, consumer, and community organizations request the opportunity to meet with you to discuss the Treasury Department’s plans for using its authority and funding under TARP to assist homeowners facing foreclosure or in imminent danger of default.

January 13, 2009 | Filed under: Mortgage, Real Estate & Housing

The Troubled Asset Relief Program (TARP) must include a foreclosure prevention program that requires those who receive funding to engage in streamlined loan modification efforts. This TARP program must be implemented quickly, whether through an agreement with the Obama Administration on core principles or through legislation consistent with the concepts in Title II of Chairman Frank's H.R. 384.

| Filed under: Mortgage, Real Estate & Housing

We appreciate the complexity of these new regulations based on the revisions to AMTPA. We agree with the Consumer Financial Protection Board (“CFPB”) that the changes made by the
Dodd-Frank Wall Street Reform and Consumer Protection Act4 necessitated the issuance of this Interim Final rule on the first day the CFPB came into legal existence. We also agree with many of
the interpretations of the new AMTPA provided by the CFPB, and we applaud the CFPB’s requirement that all variable rate indexes be beyond the control of the creditor.

However, in several, quite serious, matters the rule misinterprets both the clear language in the new AMTPA and Congressional intent. We urge the CFPB to move quickly to issue a clarifying
Interim Final rule correcting these misinterpretations.