CMLA LOBBYIST ON REG RELIEF PRIORITIES
CMLA’s Chief Lobbyist and Director of External Affairs, Rob Zimmer, laid out the strategy for pursuing CMLA’s top priorities. In a conference call with CMLA members last week, Zimmer explained why CMLA is working with the Mortgage Bankers Association (MBA) and the Community Home Lenders Association (CHLA). These Associations share CMLA’s top legislative priorities for regulatory reform.
Both CMLA and the MBA want enactment of key provisions would direct state regulators to grant a temporary license to registered loan officers employed by banks who become employed as loan officers by nonbank lenders.
The CHLA shares CMLA’s additional priorities for regulatory relief including:
- Extension of regulatory relief to nonbank small lenders
- Waiver of the three-day waiting period if borrower’s APR is reduced
- A statutory definition of “small servicer” and exemptions to CFPB servicing regulations for small servicers as defined in CMLA’s regulatory proposal (see below)
- Relief from auditing third-party vendors without regulators having reason to believe there are problems
- Relief from statistical analysis on data (expanded data fields, lenders performing statistical analysis)
- No CFPB examination or audit without a referral from state or federal agency, including FHA, FHFA, and VA, as well as a GSE
A small lender would be defined as either a bank with assets of less than $2 billion or a non-bank with net worth of less than $25 million; and, in either case, having originated no more than 20,000 mortgage loans or a gross dollar loan volume of less than $5 billion in the preceding year.
A “small servicer” would be defined as a loan servicer that owns the servicing rights to 25,000 loans or less. The exemption would apply to all small servicers, regardless of whether the small servicer performs the servicing function itself, or has some or all of the servicing functions performed by a sub-servicer.