CMLA’S 2019 Policy Agenda

  • Regulatory Relief for community-based, independent lenders
    • CFPB exams only upon referral from another regulator
    • Improving labor market flexibility by establishing a transitional license for registered loan originators moving to a new job that requires a license
    • A statutory definition of responsible, small community-based lenders that would be eligible, on an equal basis, for all current and future exemptions from regulatory requirements
  • Preserve Open, Competitive Secondary Market
    • Modernize FHA mortgage insurance program
    • Ensure open, competitive access for mid-size and small community-based lenders
    • Advocate for changes to FHA program that will affect lenders of all sizes on an equal basis and will not favor lenders of a certain size or disadvantage lenders based on their size
  • GSE Reform that will preserve equal, capital markets access for small and mid-size, independent, community-based lenders
    • Recapitalize and reform Fannie Mae and Freddie Mac
    • Convert Fannie and Freddie into utilities providing the liquidity and products to lenders that will allow them to serve the home financing needs of consumers
    • Ensure that Fannie and Freddie will continue to serve small and mid-size, community-based, independent lenders on an equal basis, including equal pricing and other terms, with all other lenders
    • Establishment of a comprehensive regulatory framework that will focus GSE purchase and securitization activity on traditional mortgage products underwritten to appropriate standards, with flexibility to address affordability needs, particularly for first time and minority buyers
  • Loan Officer Compensation
    • Allowing adjustments in the compensation paid to Loan Officers based on the following:
      • Loan originators to be allowed to voluntarily lower their compensation in response to demonstrable competition in order to pass along the savings to the consumer.
      • Loan originator’s compensation to be allowed to be reduced by the lender when the originator makes an error.
      • Lenders to be allowed to alter loan compensation in order to offer loans made under state and local housing finance agency (HFA) programs as well as those programs offered with lower margins due to specific arrangements between the lender and program sources such as portfolio lenders or independent investors.
      • CFPB to explore ways to generally simplify and clarify the LO Comp rule. The rule broadly prohibits compensation based on loan terms or proxies for terms while providing a short list of expressly permissible compensation factors.
  • QM Patch
    • To continue the QM patch indefinitely or the development of policy allowing the standards associated with the patch to be established for the industry.
Rick HamecsCMLA’S 2019 Policy Agenda