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NAFCU Support for Credit Union regulatory relief measures to be considered at Committee Mark-Up
| Good morning,
Below is NAFCU Vice President of Legislative Affairs Brad Thaler’s letter to House Financial Services Committee Chairman Jeb Hensarling and Ranking Member Maxine Waters in support of several measures scheduled to be considered during this week’s House Financial Services Committee mark-up. Members of the House Financial Services Committee were copied on the letter. In the letter, Thaler says that NAFCU strongly supports H.R. 3211, the “Mortgage Choice Act of 2013,” which would exempt from the Qualified Mortgage (QM) cap on points and fees any affiliated title charges and escrow charges for taxes and insurance. Thaler also says that the association strongly supports H.R. 2673, the “Portfolio Lending and Mortgage Access Act,” that ensures residential mortgage loans held in portfolio by the loan originator automatically qualify for the QM safe harbor. Thaler states that NAFCU also urges support for H.R. 4521, the “Community Institutions Mortgage Relief Act,” that would exempt lenders with less than $10 billion in assets from the requirement that they must hold an escrow account for five years for higher priced, first-lien mortgages secured by borrower’s principal residence. Finally, as detailed in a letter NAFCU sent to the Committee last week, Thaler says the association strongly supports H.R. 4466, the “Financial Regulatory Clarity Act,” which would eliminate duplicative, unnecessary and over-burdensome regulation. If you would like more information on this matter or would like to speak about this with a NAFCU expert, please let me know. Thank you. Dana Kauffman May 6, 2014 The Honorable Jeb Hensarling The Honorable Maxine Waters Re: NAFCU Support for Credit Union Regulatory Relief Measures to be Considered at Dear Chairman Hensarling and Ranking Member Waters: On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association exclusively representing the interests of our nation’s federal credit unions, I write today in support of several measures scheduled to be considered during this week’s Financial Services Committee mark-up. At the beginning of the 113th Congress, NAFCU called on lawmakers to enact broad-based regulatory relief for credit unions through NAFCU’s “Five-Point Plan for Regulatory Relief” to ensure they can continue to offer their 97 million members the products and services they need and deserve. The scheduled mark-up is a positive step forward in providing this type of relief. NAFCU strongly supports the bipartisan Mortgage Choice Act of 2013 (H.R. 3211), introduced by Representative Bill Huizenga, that would alter the definition of “points and fees” included in the Qualified Mortgage (QM) standard. NAFCU supports this legislative effort to exempt from the QM cap on points and fees any affiliated title charges and escrow charges for taxes and insurance. Making these important exclusions from the cap on points and fees will go a long way toward ensuring that many affiliated loans attain QM status and are still made in the future. NAFCU also strongly supports Representative Andy Barr’s legislation, the Portfolio Lending and Mortgage Access Act (H.R. 2673), that ensures residential mortgage loans held in portfolio by the loan originator automatically qualify for the QM safe harbor. Financial institutions holding loans on their books assume all risk associated with making a loan and have a strong incentive to make sure that the loan can be repaid. Additionally, NAFCU would support other additional key changes to the QM definition, including extending the safe harbor to the 40-year loan product as offered by some credit unions and including a consumer debt-to-income (DTI) ratio higher than the current 43%. The DTI ratio is particularly troubling for credit unions as they strive to serve low and moderate income segments of the population. NAFCU also urges your support for legislation introduced by Representative Blaine Luetkemeyer, the Community Institutions Mortgage Relief Act (H.R. 4521), that would exempt lenders with less than $10 billion in assets from the requirement that they must hold an escrow account for five years for higher priced, first-lien mortgages secured by borrower’s principal residence. Additionally, this legislation would amend Section 6 of the Real Estate Settlement Procedures Act (RESPA) to create a small institution exemption to reduce the regulatory burden on servicers that annually service 20,000 or fewer mortgage loans. While NAFCU believes all credit unions should receive the exemptions provided in both provisions (as we generally do not support bifurcating the industry by arbitrary asset size), this bill does provide some relief on two important issues impacting NAFCU member credit unions and we would support its passage. Finally, as detailed in a letter sent to the Committee last week, NAFCU strongly supports the Financial Brad Thaler Vice President of Legislative Affairs cc: Members of the House Financial Services Committee |