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Breaking Legislative & Regulatory Items
Appraisal and Valuation Issues
Department of Labor and the Fair Labor Standards Act
Fair Housing Act (FHA)
Government Sponsored Enterprises
Mortgage Disclosure Improvement Act (MDIA)
Regulation X (RESPA)
Regulation Z (TILA)
Regulation C (HMDA)
Risk Retention
S.A.F.E. Rule (HERA)
See Mortgage Reform Initiatives page
Dodd-Frank Act developments are tagged 
.
Appraisal and Valuation Issues
- ABA Staff Analysis: Interagency Appraisal Guidelines, January 3, 2011
- ABA Comment Letter on Interim Final Rule Amending Reg Z: Rules Regarding Appraisal Independence, December 27, 2010
- Agencies Issue Final Appraisal and Evaluation Guidelines, December 2010: The federal financial regulatory agencies issued final supervisory guidance on sound practices by financial institutions for real estate appraisals and evaluations.
- ABA Staff Analysis: Appraisal Independence Rules November 1, 2010
- Federal Reserve Issues Rule on Appraisers October 19, 2010
Department of Labor and the Fair Labor Standards Act
- ABA files amicus brief in Henry v. Quicken Loans, December 13, 2010
- Department of Labor amicus brief curiae filing in the case Henry v. Quicken Loans<, December 9, 2010
- ABA Expresses Concerns About Mortgage Loan Officers Administrative Exemption May 19, 2010
- DOL Interpretation: Mortgage Loan Officers Not 'Exempt' Employees March 24, 2010
Fair Housing Act (FHA)
Government Sponsored Enterprises
- ABA Letter to Congress urging not to Use GSE G-fee Increase to Offset Payroll Tax Cut, February 7, 2012
- ABA Comments on FCS in FHA Mortgage Insurance Programs, October 21, 2011
- Response to the Request for Information regarding disposition of REO properties held by Fannie Mae, Freddie Mac and FHA, September 15, 2011
- Coalition Letter on GSEs, March 28, 2011
- ABA Makes Recommendations Regarding the Future of Government Sponsored Enterprises, February 9, 2011
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Mortgage Disclosure Improvement Act (MDIA)
Regulation X (Real Estate Settlement Procedures Act)
- Joint ABA/Industry Comment Letter on Draft Rules for RESPA-TILA Reform (Know Before You Owe mortgage loan initiative), April 16, 2012
- ABA Amicus Brief to Supreme Court in the case Freeman v. Quicken Loans, Inc., regarding Section 8(b) of the Real Estate Settlement Procedures Act, January 10, 2012
- ABA Comments to CFPB on RESPA-TILA Integration, December 9, 2011
- ABA Comments on Amended Draft Mortgage Forms - TILA and RESPA Disclosures, August 10, 2011 See Draft Mortgage Forms
- ABA Comment Letter on Merged Mortgage Disclosures, May 27, 2011
- HUD Solicits Views on Warehouse Lending, Comments due on December 27, 2010
- ABA Comment Letter, December 22, 2010
- HUD Determines that existing RESPA rules apply to "table funding" and "secondary market transactions" in the same manner for the repurchase agreement as it would for a traditional line of credit arrangement between a warehouse lender and a mortgage lender, March 11, 2011
- Joint Trade Comments in response to Hud's solicitation for comments re: Warehouse Lending, December 22, 2010
- HUD Updates Settlement Cost Booklet July 20, 2010
- RESPA Roundup (July 2010)
- HUD Issues Advance Rulemaking Notice Regarding "Required Use" (June 2010)
- Uniform Supplemental HUD-1/1AI Instructions December 10, 2009
- HUD ANNOUNCES MORATORIUM IN ENFORCEMENT OF NEW RESPA RULES: The Department of Housing and Urban Development announces "restraint" in enforcing the newly finalized RESPA rules for the first four months of 2010 November 13, 2009
- HUD Letter to other regulators November 13, 2009
- ABA, Trade Groups Ask HUD to Postpone RESPA Rule's Implementation Date October 13, 2009
- ABA Letter Requesting Rule Suspension April 27, 2009
- ABA Comments RE: Required Use April 9, 2009
- Withdrawal of "Required Use" Definition May 15, 2009
- Final Rule November 2008
- HUD FAQs to Final Rule
- ABA's Topics page on RESPA
Regulation Z (Truth in Lending Act)
- Joint ABA-Industry letter to CFPB urging that the "qualified mortgage" (QM) designation under pending ability-to-repay rule be structured as a legal safe harbor, April 27, 2012
- Joint ABA/Industry Comment Letter on Draft Rules for RESPA-TILA Reform (Know Before You Owe mortgage loan initiative), April 16, 2012
- Joint ABA-Industry Letter to CFPB urging for the necessity of broadly‐defined Qualified Mortgage (QM) April 13, 2012
- CFPB Bulletin on MLO Compensation Rules and contributions to Qualified Plans, April 2, 2012
- ABA Comments to CFPB on RESPA-TILA Integration, December 9, 2011
- ABA Letter to the Bureau on QM, MLO Compensation and other regulatory issues, August 12, 2011
- ABA Comments on Amended Draft Mortgage Forms - TILA and RESPA Disclosures, August 10, 2011 See Draft Mortgage Forms
- ABA Comment Letter on Proposed Rule Amending Regulation Z: Ability-To-Repay Requirements, July 22, 2011ABA Comment Letter on Merged Mortgage Disclosures, May 27, 2011
- ABA Comment Letter on the Board's Proposal Regarding Mandatory Escrow and Disclosures on Higher Priced Mortgage Loans (HPMLs), May 2, 2011
- Fed Proposes Minimum Mortgage Underwriting Standards, April 19, 2011
- ABA Staff Analysis: Ability to Repay Rule
, June 3, 2011
- ABA Staff Analysis: Ability to Repay Rule
- ABA Comment Letter on Truth in Lending (TILA) Regulation Governing Compensation to Mortgage Loan Originators, March 29, 2011
- ABA Staff Analysis: Final Rule on Rules for Higher-Price Mortgage Loans— Mandatory Escrow for Jumbo Loans, March 10, 2011
- ABA Comment Letter on Interim Final Rule Amending Reg Z: Rules Regarding Appraisal Independence, December 27, 2010
- ABA Urges FED To Calibrate Reg. Z Changes With Dodd-Frank Rules, December 23, 2010
- Joint Trade Letter to Fed on Reg Z (TILA) Reverse Mortgages December 22, 2010
- Comment on Interim Rule Amending Regulation Z: Summary Information Regarding Interest Rates and Payment Changes, November 23, 2010 See ABA Staff Analysis
- ABA Staff Analysis: Appraisal Independence Rules November 1, 2010
- Federal Reserve Issues Rule on Appraisers October 19, 2010
- Board issues proposed enhancements to consumer protections and disclosures for home mortgage transactions, including significant changes to Regulation Z that represent the second phase of the Board's comprehensive review and update of the mortgage lending rules in the regulation August 16, 2010 See ABA Staff Analysis and Comment Letter
- The Board issues final rules to protect against unfair, abusive, or deceptive lending practices arising from loan originator compensation practices. New rules apply to mortgage brokers and the companies that employ them, as well as mortgage loan officers employed by depository institutions and other lenders August 16, 2010 See ABA Staff Analysis See ABA FAQ's, April 1, 2011
- Federal Reserve announces final rules regarding consumer notification of mortgage loan sales or transfers (Section 404 of Helping Families Save Their Home Act), August 16, 2010.
- The Board issues interim rule revising disclosure requirements for closed-end mortgage loans and implementing provisions of the Mortgage Disclosure Improvement Act (MDIA) that require lenders to disclose how borrowers' regular mortgage payments can change over time August 16, 2010. MDIA Final Rule II, ABA Staff Summary. ABA Comment Letter November 23, 2010
- Federal Reserve proposes rule to revise escrow account requirements for jumbo mortgages August 16, 2010
- ABA Suggests Alternatives to Mandatory Escrow Requirements for Smaller Banks March 12, 2010
- Board Interim Rule on Sec. 404 of the Helping Families Save Their Homes Act November 16, 2009
- ABA to Fed: Reg Z Rules Having Detrimental Impact November 4, 2009
- Federal Reserve Letter to Hud September 29, 2009
- ABA Joint Trade Letter on FHA and HPMLs September 23, 2009
- Proposed Rule to amend Regulation Z August 26, 2009
- Revised Rule for disclosures of Closed-end Credit secured by real property or dwelling August 26, 2009
- ABA FAQs to MDIA Rule August 17, 2009
- 2009 Adjustment to HOEPA Fee Based Triggers August 10, 2009
- Proposed Rule on Closed-end Mortgages and HELOCs July 23, 2009
- MDIA Final Rule May 19, 2009
- ABA Comments to FRB February 9, 2009
- HOEPA Final Rule July 30, 2008
- ABAWorks on HOEPA Final Rule July 2008
- ABA Comments to FRB April 8, 2008
Regulation C (Home Mortgage Disclosure Act)
- ABA Topics page on Home Mortgage Disclosure Act (HMDA)
- 2009 HMDA Data Now Available September 20, 2010
- FFIEC Releases 2008 HMDA Data September 30, 2009
- Federal Reserve Issues Draft Bulleting Article on 2008 HMDA Data
- HMDA Final Rule October 24, 2008
- ABA/Inter-industry Comments to FRB August 29, 2008
- Updated guidebook "HMDA: Getting It Right for 2009"
Letter to CFPB on Alternative Mortgage Transaction Parity (Reg D), September 22, 2011
ABA Comment Letter on Proposal to Establish Credit Risk Retention Requirements, August 1, 2011
S.A.F.E. Rule (Housing and Economic Recovery Act of 2008)
- Agencies Announce Start of Initial Registration Period under MLO Provisions (1/31/11)
The OCC, Federal Reserve Board, FDIC, OTS, FCA, and NCUA (the Agencies) are issuing a notice announcing that the initial registration period for Federal registrations required by the Secure and Fair Enforcement for Mortgage Licensing Act (the S.A.F.E. Act) is now open and will run from January 31,2011 through July 29, 2011. Following expiration of the 180-day initial registration period on July 29, 2011, any employee of an agency-regulated institution who is subject to the registration requirements will be prohibited from originating residential mortgage loans without first meeting these requirements. For questions, contact ABA's Rod Alba. - ABA Letter on State Regulatory Registry Board's proposal to set fees in accordance with the SAFE Act, November 12, 2010
- ABA Staff Analysis: Secure and Fair Enforcement for Mortgage Licensing Act September 2010
- Agencies Adopt Rule Implementing Mortgage-Originators Registration System July 28, 2010
- Joint Comments on Licensing State Standards March 5, 2010
- FDIC Board of Directors has approved draft final rules implementing the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE Act) The rule has been posted on the FDIC's Web site, but will not be published in the Federal Register until the other agencies (OCC, OTS, FRB, FCA, NCUA) involved in this rulemaking complete their review and approval of the rule.
- Joint Notice of Proposed Rulemaking June 9, 2009
- ABA Comments July 9, 2009
Questions? Please contact Rod Alba for more information.
