Analysis of OCC Guidelines Establishing Standards for Residential Mortgage Lending Practices
While we are heartened that the OCC has recognized many of the issues raised by state anti-predatory lending efforts in recent years, the OCC’s guidance for national banks is no substitute for meaningful and effective legislative efforts at the state and federal level. Further, we are disappointed that the OCC does not identify some practices as clearly predatory and take a stronger stance on enforcing rules that prohibit banks from engaging in predatory lending.
The Guidelines demonstrate recognition of some predatory lending issues, but are insufficient to protect homeowners from abusive lending practices compared to state and federal legislation.
Date: February 3, 2005
Agency(-ies): Office of the Comptroller of the Currency (OCC)
CRL feels OCC’s guidance for national banks is no substitute for meaningful and effective legislative efforts at the state and federal level.