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MBA Files Comment on Proposed Risk Retention/Qualified Residential Mortgage Rule

MBA Files Comment on Proposed Risk Retention/Qualified Residential Mortgage Rule

WASHINGTON, D.C. – August 2, 2011 – (RealEstateRama) — Members of Media:On Monday, the Mortgage Bankers Association (MBA) filed a comment letter with six federal regulators in response to proposed credit risk retention regulations implementing section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

In the comment letter, MBA’s President and CEO David H. Stevens reiterated MBA’s support for risk retention requirements as an important step in establishing a better regulatory plan to protect borrowers and investors, and ensure a safe and reliable mortgage system, but expressed serious concerns about parts of the Qualified Residential Mortgage (QRM) definition, the Premium Reserve Cash Capture Account (PCCRA), risk retention duration and several other considerations.

The full comment letter can be found here.

Note that the views and recommendations in this letter are from the single family residential mortgage finance perspective.  For MBA’s comment letter from a commercial/multifamily real estate finance perspective, click here.

If you have any questions, please contact John Mechem, Vice President of Public Affairs at (202) 557-2924, ">.


The Mortgage Bankers Association (MBA) is the national association representing the real estate finance industry, an industry that employs more than 280,000 people in virtually every community in the country. Headquartered in Washington, D.C., the association works to ensure the continued strength of the nation’s residential and commercial real estate markets; to expand homeownership and extend access to affordable housing to all Americans. MBA promotes fair and ethical lending practices and fosters professional excellence among real estate finance employees through a wide range of educational programs and a variety of publications. Its membership of over 2,400 companies includes all elements of real estate finance: mortgage companies, mortgage brokers, commercial banks, thrifts, Wall Street conduits, life insurance companies and others in the mortgage lending field.


Mortgage Bankers Association
1331 L Street, NW
Washington, DC 20005

Phone: (202) 557-2700