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Statement on CFPB Mortgage Servicing Transfer Bulletin
State Regulators Support CFPB’s Small Creditor Proposal under Ability to Repay
Missouri Division of Finance Receives Re-Accreditation
Multi-State Mortgage Committee Issues 2012 Annual Report to State Regulators
Three Appointed to FFIEC State Liaison Committee
New SAFE MLO Test with Uniform State Content Now Available
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Chairman of FFIEC State Liaison Committee Announced
Federal Reserve, CSBS To Host Community Banking Research Conference
Federal Reserve’s Foreign Bank Proposal Should Further Contemplate Existing State Supervision
Lawson Appointed to FFIEC State Liaison Committee
CSBS Releases 2012 Annual Report
James M. Cooper Named CSBS Senior Vice President
CSBS Announces 2013-2014 Board & Officers
CSBS and CFPB Sign Supervisory Framework
CSBS Immediate Past Chairman Calls for Balanced Financial Supervision
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FFIEC Forms Cybersecurity and Critical Infrastructure Working Group
State Regulator Testifies on the Perils of One-Size-Fits-All Supervision
Ten More States to Use Uniform Mortgage Test; 30 States Now Using the Test
Approach to Basel III Respects Industry Diversity
NMLS 2013 State, Federal Mortgage Industry Reports Released
Michael J. Belak Named CSBS Vice President
North Dakota Banking Department Maintains Highest Standards in Bank Supervision
Iowa Division of Banking Receives Bank Re-accreditation
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Oct. 2-3 Fed/CSBS Community Banking Research Conference To Be Broadcast Live from St. Louis
H. Catherine Woody Promoted to Vice President, Media & Industry Relations
Five More States to Use Uniform Mortgage Test; 35 States Now Using the Test
Federal Reserve and CSBS Release 2013 Community Banking Report
Georgia Department of Banking and Finance Receives Re-accreditation
CSBS Highlights Fed Board’s Evolving Composition, Supervisory Role
Texas Department of Banking Receives Re-Accreditation
CSBS Announces Promotions in its Technology, SRR Divisions
President Should Consider Supervisory Experience When Filling Fed Board
States Look to Coordination and Existing Regulatory Framework to Oversee Virtual Currencies
State Regulators to Discuss 2014 Outlook in On-the-Record Session with Media
Michigan Department of Insurance and Financial Services Office of Banking Receives Re-Accreditation
CSBS White Paper Encourages Federal Policymakers to Right-Size Regulations
Nebraska Department of Banking and Finance Maintains Highest Standards of Bank Supervision
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 2/26/2013 

Media Release

Conference of State Bank Supervisors
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American Association of Residential Mortgage Regulators
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American Council of State Savings Supervisors
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 State Regulators Support CFPB’s Small Creditor Proposal under Ability to Repay   

Washington, D.C. – The Conference of State Bank Supervisors (CSBS), the American Association of Residential Mortgage Regulators (AARMR) and the American Council of State Savings Supervisors (ACSSS) submitted a joint comment letter Monday to the Consumer Financial Protection Bureau (CFPB) expressing strong support of a proposed small creditor amendment to the agency’s Ability to Repay rule.

The joint comment letter endorses the CFPB’s small creditor qualified mortgage (QM) definition and backs the increased average prime offer rate for the small creditor QM, which recognizes the increased costs of doing business for small creditors.

“CSBS, AARMR and ACSSS have long standing policy that regulations should not hinder an insured depository institution’s willingness to engage in portfolio lending, and this proposed rule would make it easier for such institutions to extend credit and retain the risk thereof,” the organizations wrote.

The organizations said the CFPB’s proposal properly summarizes the small creditor’s aligned interest with consumer protection and recognizes the strong incentives small creditors have to carefully consider a potential borrower’s ability to repay a portfolio loan because the creditor retains the risk of default.

The organizations also support the increased average prime offer rate thresholds for small creditors that, as proposed, would provide added room for increased legal protection conferred by the qualified mortgage definition.  “As noted in the proposal, many small creditors are the predominant source of credit in areas where large creditors do not operate. Small creditors fill this gap with a business model crucial to our nation’s economy,” the organizations wrote.

While largely supportive of the proposed small creditor amendment, CSBS, AARMR and ACSSS also asked the CFPB to provide more clarity in the proposal regarding what constitutes an originated loan, and suggested the agency revisit the proposed thresholds in the future for evaluation of market trends.

The joint comment letter is available here. The CFPB’s concurrent proposal to the Ability to Repay Rule is available here

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