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NAMB comments on Fed proposed rule amending Regulation Z
Dec 28, 2009

The National Association of Mortgage Brokers (NAMB) has submitted comments to the Federal Reserve Board (The Board) on the Proposed Rule amending Regulation Z. NAMB commends the Board for its efforts to fix problems that exist in the mortgage market, however certain aspects of the Proposed Rule will impede competition, fail to reflect the most current and authoritative research, and/or do not consider the most effective and least burdensome alternatives. “As currently written, the Proposed Rule will undoubtedly cause unintended consequences that will hurt consumers and the housing market,” said NAMB President Jim Pair, CMC. “The Board has failed to consider how these proposals will impact an already significantly changed mortgage landscape.” NAMB’s comments present an analysis of the Proposed Rule in light of current market realities, relevant studies, available data, and applicable law. NAMB evaluates the Proposed Rule’s goals and rationales, and explores which elements of the Proposed Rule would effect meaningful and beneficial change, and which present serious issues for consumer and our mortgage market. Also, where appropriate, NAMB offers alternatives that it believes would better serve consumers and the market. “NAMB is seriously concerned with The Board’s proposals on originator compensation because they limit a consumer’s choice in deciding how to finance a mortgage loan,” said Pair. “Furthermore, whether or not it was The Board’s intent, the proposals pick winners and losers among competing entities within the marketplace by only regulating the manner of compensation for some. Small businesses offering mortgage loan origination services will be negatively and disproportionately impacted by the Proposed Rule. NAMB is also disappointed in the Board’s characterization of payments to mortgage broker companies as ‘unfair and deceptive trade practices’ with the knowledge that lenders, banks and credit unions receive the same such payments but are not categorized in the same manner.” NAMB strongly recommends that The Board be consistent with other proposed financial reform by delaying implementation of a final rule until after Congress acts upon proposed legislation to create a Consumer Financial Protection Agency under HR 4173. Also, NAMB recommends that the anti-steering language included in the Proposed Rule be to be consistent with anti-steering language included in HR 4173. “We encourage the Board to adequately dissect and consider NAMB’s recommendations to prevent unintended harm to the consumer and further impede the housing recovery,” said Pair.  For a copy of NAMB's comment letter, click here. For more information, visit
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