Mortgage Bankers fight the CFPB
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Mortgage Bankers fight the CFPB






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    Mortgage Bankers fight the CFPB Mortgage Bankers fight the CFPB Document Transcript

    • May 11, 2011The Honorable Spencer Bachus The Honorable Barney FrankChairman, Committee on Financial Services Ranking Member, Committee on Financial Services2129 Rayburn House Office Building B371A Rayburn House Office BuildingWashington, DC 20515 Washington, DC 20515Dear Chairman Bachus and Ranking Member Frank:On behalf of the Mortgage Bankers Association, I am writing to express our support for H.R. 1121,the Responsible Consumer Financial Protection Act, and H.R. 1315, the Consumer FinancialProtection Safety and Soundness Improvement Act.During the year-long debate over the Dodd-Frank Wall Street Reform and Consumer ProtectionAct (Dodd-Frank), MBA consistently supported the legislations underlying goal of mergingdisparate consumer financial regulatory functions under one roof. The creation of the Bureau ofConsumer Financial Protection (CFPB), while achieving that goal, did so at the expense ofassuring sufficient oversight and appropriate governance of the CFPB – something these two billsaim to rectify.H.R. 1315 would strengthen the power of the Financial Stability Oversight Council (FSOC) – theboard of federal financial regulators established under Dodd-Frank – to review, and wherenecessary overrule, the CFPB’s rulemaking. In establishing a CFPB review function for theFSOC, Congress wisely recognized the importance of assuring that safety and soundnessconsiderations were considered in carrying out the CFPB’s responsibilities, yet the final billestablished too high a threshold for the FSOC to overturn the CFPB’s rules, rendering the FSOC’soversight powers all but ineffective. H.R. 1315 will achieve a more appropriate balance of thesecrucial but oftentimes competing concerns.H.R. 1121 would improve the CFPB’s governance by replacing its single director with a 5-membercommission. This is the governing structure for numerous independent regulatory agenciesincluding the Federal Deposit Insurance Corporation, the Securities and Exchange Commissionand the Consumer Product Safety Commission, to name a few. A commission structure assuresjudicious consideration of a range of viewpoints in carrying out regulatory functions withappropriate involvement of representatives of both parties and a range of interests including thoseof consumers and the industry.Thank you for the opportunity to comment on the bills your committee is considering.Sincerely,David H. StevensPresident and CEO 1717 Rhode Island Avenue, NW | Washington, DC 20036 | | (202) 557-2700