Thursday’s Advocacy & Think Tank Round-Up

  • The Federal Reserve Bank of NY’s Center for Microeconomic Data has released its 3rd quarter Household Debt and Credit Report which shows that Mortgage debt, the largest component of household debt, increased in by $144 billion since the 2nd quarter of 2015.  Balances on Home Equity Lines of Credit decreased by $7 billion.
  • The Mortgage Bankers Association (MBA) sent a letter to the Federal Housing Finance Agency, which oversees Fannie Mae and Freddie Mac, proposing that advocating upfront risk sharing targets be set for 2016.  This proposal is prompted by FHFA’s near doubling of insurance fees, which are necessary to reduce the risks borne by the taxpayer when debtors default.  The MBA is advocating for private opportunity to compete in the insurance of these loans – which they say will lead to lower fees for borrowers as well.
  • The National Association of Realtors (NAR) has released its Pending Home Sales Index for October which inches up .2% to sustain 14 consecutive months of increase.  NAR also is predicting another housing boom for 2016.

Reiss on Home Mortgage Disclosure Act Proposed Rulemaking

I have submitted a Comment on Home Mortgage Disclosure Act Proposed Rulemaking to the Consumer Financial Protection Bureau.  Basically, I argue

The Consumer Financial Protection Bureau’s Home Mortgage Disclosure Act proposed rulemaking (proposed Aug. 29, 2014) is a reasonable one.  It increases the amount of information that is to be collected about important consumer products, such as reverse mortgages.  It also increases the amount of important information it collects about all mortgages.  At the same time, it releases lenders from having to determine borrowers’ intentions about how they will use their loan proceeds, something that can be hard to do and to document well.  Finally, while the proposed rule raises some privacy concerns, the CFPB can address them.