CBA Responds to CFPB’s Request for Information on Mortgage Market Dynamics
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.