TMHA Files Comment Letter to CSBS on Mortgage Servicing Proposal

On March 25, 2015, the Conference of State Bank Supervisors (CSBS) and the American Association of Residential Mortgage Regulators (AARMR) issued for public comment Proposed Regulatory Prudential Standards for Non-bank Mortgage Servicers.  TMHA along with our national association, MHI, and other state associations and interested parties submitted comments to the published executive summary of the proposed regulatory standards. 

The main concern addressed in TMHA’s comments are the impact such standards would have on smaller, in particular portfolio, lenders in the manufactured housing space.  The proposed standards would seek to increase capital and liquidity standards for servicers as well as add additional layers of regulatory complexity and compliance burdens.

At this early stage the proposed standards are far from becoming a reality.  The CSBS could eventually arrive at final recommended standards that would then have to be adopted by each state.  However, we are taking this proposal seriously and will continue to work even in the infancy stages because we have seen firsthand in the past what can happen based on CSBS recommendations.  For those who may have forgotten, the SAFE Act was originally conceived by the CSBS in similar fashion and then came into federal law with its state adoption mandate.

For TMHA members interested, you can read our comment letter.