In response to a request made by representatives from the Consumer Financial Protection Bureau (CFPB) during a recent meeting with CBA’s president and CEO, Simone Lagomarsino, we have shared with the bureau information providing evidence of the shifting marketplace dynamics relative to residential mortgage loan origination and mortgage servicing. The CFPB requested that we share additional data identifying the marketplace trends. In furnishing the CFPB with this information we underscored that the data is illustrative of current trends and should not be considered exhaustive research.

Overall, the data substantiates our observation of the decline in residential mortgage loan originations and mortgage servicing by banks and an increase in those same activities by non-bank entities. In corresponding with CFPB, we have suggested that regulators may wish to become familiar with this trend as they consider the appropriate degree of regulatory support offered to the various license types originating and servicing residential mortgage loans and the intensity and scope of their periodic examinations for such entities. Further, given the decline in residential mortgage loan originations and mortgage servicing by banks, regulators may wish to consider regulatory reforms that stimulate bank re-entry into residential mortgage loan origination and mortgage servicing.  

We hope that you will find the sampling of data that we shared with the CFPB informative. Please do not hesitate to contact us with any questions.