ABA Letter to CFPB on Mortgage Fees RFI

Re: Request for Information Regarding Fees Imposed in Residential Mortgage Transactions; Docket No. CFPB-2024-0021

To Whom It May Concern:

The American Bankers Association (ABA) appreciates the opportunity to comment on the Consumer Financial Protection Bureau's (CFPB or Bureau) request for information (RFI) regarding fees imposed in residential mortgage transactions. ABA appreciates the Bureau's study of closing costs and the impact they have on borrowers and the mortgage market. ABA and its members share the Bureau's interest in enhancing mortgage market operations and promoting competitive pricing.

This letter supplements joint trade association comments submitted in this docket, which discuss important principles that the Bureau must observe in connection with any future policy actions regarding mortgage settlement fees. In these comments, we advance bank-specific responses to several questions posed by the RFI.

In the RFI, the Bureau notes recent steep increases in settlement and other costs related to home mortgages and seeks to understand the factors that drive these fee increases and how the fees are affecting housing affordability and access to homeownership. Our responses focus on the following questions posed in the RFI: (i) whether every fee charged is necessary to close the loan, (ii) who profits from the various fees, (iii) who benefits from the services provided, and (iv) what leverage or oversight lenders may have over third-party costs that are passed onto the consumer.

Download the comment letter to read the full text.

ABA Letter to CFPB on Mortgage Fees RFI

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ABA Letter to CFPB on Mortgage Fees RFI

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