TBMA Submits Comments to the FDIC on Guidance Regarding Predatory Mortgage Loans
The Bond Market Association (TBMA)* provides comments to theFederal Deposit Insurance Corporation (FDIC) onguidance regarding predatory mortgage loans, Draft FDIC Staff Memorandum: How to Avoid Purchasing or Investing in Predatory Mortgage Loans. The FDIC guidance encourages banks regulated by the FDIC to adopt certain steps aimed at curbing the purchase or funding by banks of predatory loans as well as investment by banks in securities backed by those loans. TBMA believes in several respects the proposals would impose subjective and unreasonable responsibilities on secondary market participants.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.