From MMBA e-news on December 24, 2009:
Attached are links to download your Association's (MMBA) comment to the Federal Reserve pertaining to the August 26, 2009 PROPOSED rule amending Regulation Z 74 Fed. Reg. 43232. This reflects a great deal of work by your Compliance Committee and your Board of Directors.
Although the proposed rule is detailed and complex as addressed very adequately by both the National Mortgage Bankers Association and the National Mortgage Brokers Association as attached, the MMBA focussed attention on three critical elements: a delay of implementation; interest and settlement charges; and loan originator and broker compensation.
With regard to compensation, the Association simply refers the Federal Reserve Board to adopt the Massachusetts Attorney General Ch. 93A and 940 CMR 8.00 definitions and clarifications of compensation which does NOT prohibit the compensation through a Yield Spread Premium but prohibits the arrangement of a mortgage loan that is not in the consumer's interest and that shall not present a conflict of interest between the loan originator's compensation and consumer's loan terms and interest.
The Massachusetts mortgage industry has appeared to have adapted fairly well to the AG's regulations and hence, should serve as a model for the Federal Reserve.
Please be forewarned that all of the documentation attached amounts to well over 100 pages but clearly outlines the MMBA's public comment and referral to the AG regulations, FAQ’s and both national Association testimony.
This is one more excellent example of your MMBA trying its very best to earn your membership investment. If you have any questions or comments, please do not hesitate to contact me.
Happy Federal Reserve Comment Period!!
kmc ~
Kevin M. Cuff, MPA
Executive Director
Massachusetts Mortgage Bankers Association
617/570-9114
kmcuff@massmba.com
