Mortgage Bankers Association Letter to the Federal Reserve RE “Skin in the Game” and the Ability of Borrowers to Repay

Mortgage Bankers Association Letter to the Federal Reserve RE “Skin in the Game” and the Ability of Borrowers to Repay

The MBA believes this proposal and the Credit Risk Retention/Qualified Residential Mortgage
(QRM) rule, to which we are responding in a separate comment letter, are the two most
significant mortgage-related rules required by Dodd-Frank concerning mortgage lending. How these rules are finalized will determine who has access to affordable mortgage financing for generations to come.

Please do not hold us accountable for pushing predatory loans! First, if you make the originators keep some “skin in the game” the mortgage market and global economy will be destroyed!

Second, you can’t possibly expect lenders to lend to people who can actually pay the loan back do you?

Dodd-Frank and this proposal prohibit lenders from making a mortgage loan unless the
originator makes a reasonable determination, in good faith, based on verified and documented
information at the time the loan is consummated that the consumer has a reasonable ability to repay the loan, including all applicable taxes, insurance and assessments.

MBA has long supported establishment of an ability to repay requirement for mortgage loans.
However, since the requirement will apply broadly and bring considerable liability to lenders and assignees for any violations, it is essential that the rule’s QM requirements include
unambiguous definitions and means of compliance. Clear “bright line” requirements will ensure the provision of sustainable mortgage credit to the widest array of qualified borrowers at affordable costs.

If these requirements are implemented incorrectly, however, we are deeply concerned that far too many borrowers will be excluded from affordable mortgage credit and/or will be subject to unreasonably increased financing costs, in turn harming the very people Dodd-Frank was intended to protect and undermining the nation’s economic recovery.

Actual letter below…

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4closureFraud.org

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MBA Ability to Repay Comment Letter

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Comments
14 Responses to “Mortgage Bankers Association Letter to the Federal Reserve RE “Skin in the Game” and the Ability of Borrowers to Repay”
  1. Jim Bethea says:

    When you take a close look at Congress you must come up with one of two decisions???
    1. If our congress persons are so stupid that they do not understand how the Fed Res is just an illegal cartel stealing billions per year from the taxpayers, then they are too stupid to hold their position in our government….

    2. If our congress understands the Fed Res and how they have endorsed the banking fraud for many. many years ~ then they should be in jail with the other perpurtrators……..

    The Federal Reserve under Greenspan’s watch begged congress to give them more “alternative means” of financing since the homeowership was growing by leaps and bounds ~~ The Birth of the Adjustable Rate Mortgages ~~ What a fraudulent scam to steal people’s properties ~~

    I loved seeing Jeb Hensarling from Texas asking Greenspan about his asking congress to promote the ARM and lower standards for qualifying loans ~~ Greenspan said he did do this and had no recollection of such ~~ Then Jeb looks around at one of his aids and looks back at Greenspan and says: “I think we have a video of the hearing where you did request authorization of the ARM, would you like to see it now??? hee hee

    Of course Greenspan declined to see it ~~ one of the biggest crooks in quite a while until Bernanake, Paulson and Geithner………….but they are just puppets doing as told by the Illuminati …..

  2. WHAT DO THESE IDIOTS IN THE WHITEHO– USE THINK, WHEN THEY HAVE HELPED TO PUT THE TAX PAYERS OUT OF BUSINESS AND JOBS? THEY PUT THEIR EMPLOYERS OUT OF INCOMES. THEY ARE EMPLOYED BY US. WHERE DO THEY THINK THE MONEY COMES FROM ? THE BANKS.? KICKING THE HORSE THAT FEEDS THEM IN THE MOUTH, THEN COMPLAIN THEY HAVE NO FUNDS. THEY HAVE ALL BEEN IN THEIR OWN LITTLE FAIRTALE WORLD OF THE GREEDY AND CORRUPT. NIW THAT THEY HAVE RAN OUT OF MONEY, MAYBE THEY WILL SEE THE NEED NOT TO BE GREEDY. GREED CAN ONLY GET THEM SO FAR. TO BAD AMERICA HAS TO GO TO HELL BEFORE THEY GET A CLUE!.

  3. lvent says:

    That stupid biyatch Pelosi is saying she is disturbed by the lack of revenue in the debt bill…WTF????? I heard a report that SIXTY PERCENT OF THE COUNTRY IS OUT OF WORK AND OUT OF THE REMAINING 40 PERCENT WHO ARE WORKING, HOW MANY OF THOSE ARE UNDEREMPLOYED OR ARE NOT MAKING ENOUGH MONEY TO KEEP UP WITH THE RISING COST OF FEDERAL RESERVE INFLATION OF GOODS AND SERVICES AND DEFLATION OF THE VALUE OF THE DOLLAR????? Stop PLAYING DUMB PELOSI, YOU KNOW THEIR ELITE FOREIGN MULTINATIONAL GAME PLAN TO WEAKEN US AS A NATION WAS TO DESTROY OUR ECONOMY…….JUST LIKE THE LAST GREAT DEPRESSION EXCEPT WE MIGHT JUST BE WEIMAR GERMANY THIS TIME AROUND… THE DEVILS ARE ALL HERE…………….YOU ARE ALL GETTING THROWN OUT ON YEARS NEXT ELECTION, BOTH REPUBLICON AND DEMORAT………….THE ONLY TERROR WARNING THE AMERICAN PEOPLE MUST BE AWARE OF IS THE TERROR FROM WITHIN OUR OWN NATION…….THEY HAVE INFILTRATED OUR GREAT NATION AND HAVE CONDUCTED A SNEAK ATTACK ON OUR FREEDOM AND OUR NATIONAL SOVEREIGNTY………WE THE PEOPLE MUST ROUT THEM OUT BY EXPOSING THEM AND REMOVE THEM.

    • lvent says:

      THE OBAMA DECEPTION IS-THEY ARE ALL A DECEPTION, IN BOTH PARTIES…….THEY ARE ALL CORRUPT AND — USELESS TRAITORS AND TREASONISTS TO THE UNITED STATES OF AMERICA…WE THE PEOPLE MUST THROW THEM OUT ON THEIR HEADS…STOP COOPERATING WITH THIS FOREIGN TYRANNY BY USING CREDIT, DEBIT AND THE MULTINATIONAL BANKS….DON’T BUY ANYTHING ON THEIR CREDIT, NOT CARS, NOT COLLEGE LOANS, NOT HOMES. F#@K THEM……THEY HAVE RANG THIS NATION UP WITH ENOUGH SPECULATED DEBT……THE WALL STREET/FEDERAL RESERVE CROOKS ARE MAKING TRILLIONS OFF OF THAT NEW DEBT. THE ONLY WEALTH THEY KNOW HOW TO CREATE IS IN THIS PONZI SCHEME OF CREDIT. THE FOREIGN MULTINATIONAL WALL STREET BANKSTERS HAVE CREATED A CREDIT INDUCED CLUSTERF#@K RIGHT TO THE POOR HO– USE FOR ALL OF US…LIVE WITHIN YOUR MEANS AMERICA, DUMP THE CREDIT OR THE CREDIT WILL DESTROY US…JUST STOP PAYING AND ALLOWING THEM TO CREATE NEW DEBT FOR ALL OF US AND FOR THEM TO MAKE MONEY ON AND ALL OF US TO BECOME WEAK DEBT SLAVES………THEY HAVE FORCED ALL OF US TO PAY FOR THEIR PONZI SCHEME OF DEBT CREATION…….DEMAND AN.END TO THE WAR MACHINE…..CREATE WEALTH AT HOME AND SCREW THEM…..

      • lvent says:

        FOOD FOR THOUGHT: 97% OF THE DEBT IN AMERICA IS UNSECURED DEBT…YOU HAVE THE POWER TO STOP YOUR OWN DEBT ENSLAVEMENT…..

  4. lvent says:

    All of our FOREIGN ENEMIES both inside of America and outside of America and their UNITED STATES traitor minions are almost giddy today talking about wanting to see our downgrade..Bloomberg TV is reporting..Putin is saying the US. IS LEACHING OFF THE WORLD AND OUR CURRENCY NEEDS TO BE DOWNGRADED.WTF???.Blackrock Pimco is saying the U.S. will be downgraded. The purchase of credit default swap insurance is down….WALL STREET and the FED did this to our great country and now ALL OF THE DEVILS ARE WAITING AND WATCHING FOR THE U.S. TO FALL. Funny thing is if we go down they are ALL going down with us…None of them would be shit without us so therefore if the U.S.. fails they will all be flushed down the toilet right with us…..

    • lvent says:

      THESE FOREIGNERS ALL FORGET WHO SAVED THEIR ASSESS FROM THIS TYRANNY LAST TIME THEY DID THIS TO THE WORLD……IT WAS THE UNITED STATES OF AMERICA!!!!!!!!!!!!!!!!!!!!!!!! WE THE PEOPLE WILL DO IT ONCE AGAIN.

  5. housemanrob says:

    This is an endless crime scene that just keeps on sustaining and reigniting itself…….but cannot fuel itself without the guidance of the criminals behind it. Let’s take a look at this picture…..our courts and judges cannot seem to get it…..red flag!……they do!…….is judge Schack having any trouble figuring it out?,……..he just retorts that the plaintiff lawyers have some nerve bringing this shit in front of his court……he is even dragging robo-signers to depose. How about Sharon Bock stating that fraudulent recordings were not her problem…..the antithesis of Jeff Thigpen, who is digging thru files like a chicken with his head cut off! We have the great Charlie green, clerk of court, Lee county, etc. etc, so this cancer has spread everywhere and it will not be cured by a round of radiation and chemotherapy. Where is our leadership….where is the integrity, the caring enough to do the right thing! Who the hell did we vote for!

    • Don’t be fooled….the courts DO GET IT…..they are following the orders of an oath that is not American…same with all the lawyers…Some Judges have integrity…a deep concern for the people of America…Rare,,,but some Judges and lawyers know what to look for, perfect wording in the courts, and the drive to stick to the American way and the Laws. The rest of the low lifers may follow the money or are living in fear of the oath. I would imagine the judges are under the same oath as the lawyers…the British Guild oath….the British ( QUEEN) rubbing noses with the Black Pope….and the nazi’s. As far as this Charlie Green goes…he has made his bed with the culprits with his promise to not be unloyal…he speaks tough only because he feels the security of the BIG GANG behind him….take that away and he will go into hidding…Lee County has not been happy with him…, no one needs to threaten him..he is his own enemy…..he lives with that everyday.

    • lvent says:

      The people were swindled Rob into voting in the same crooks who put us here…..The Republicon/Demorat paradigm is corrupt and useless. The Republicons are tyrants and the demorats are hostages to this tyranny because they too are corrupt…..They are mainly all traitors and treasonists.. We need to rout them out by exposing them and their owners…FOLLOW THE MONEY……What are their investments and who funded their campaigns. The mainstream media will not tell you the truth..unless you are in the right place at the right time sometimes they will let the truth slip…Bottom Line,,,,DO NOT TRUST, VERIFY……..Our votes don’t count because rampant deceit is covering up for all of their lies and corruption………We are living in the age of the world wide web and people need to do their homework and find out for themselves who these people are outside of the mainstream media with the use of alternative media sources……..

  6. Readdocs says:

    Obviously the players wish to return to the same broken system that caused the fractures
    in the economics of America. Why didn’t he just blame Bush and global warming as well.
    That letter is the direct effect of not having any skin in the game and why it was written
    in such a context. Of course they wish to return to no skin in the game, it’s what made them
    so rich!

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