Recent proposals call for requiring prospective homeowners to make a 10-20 percent down payment when purchasing a home. This is seen as “getting back to the way mortgages were made in the 1980s.” In fact, low down payment home loans have been a significant—and safe—part of the mortgage finance system for decades, bearing little resemblance to subprime and other alternative mortgage products that crashed our economy. And responsible low down payment loans are also a key to the recovery of our nation’s housing market and economy

A diverse group of national civil rights, labor and consumer organizations writes regulators to share their views with respect to the regulation of securitizers of residential mortgage loans.

CRL and other advocates join mortgage industry leaders in urging regulators to carefully consider how they define mortgages that will be exempt from certain rules. An overly narrow definition could unnecessarily tighten access to home loans.

The National Consumer Law Center ("NCLC") respectfully submits the following comments on behalf of its low income clients, as well as Americans for Financial Reform, California Reinvestment Coalition, the Center for Responsible Lending, Consumer Action, Consumers Union, National Association of Consumer Advocates, National Community Reinvestment Coalition, National Fair Housing Alliance and the Neighborhood Economic Development Advocacy Project, regarding the Federal Reserve Board‘s proposals to revise numerous regulations under the Truth in Lending Act (―TILA‖) governing home-secured lending.

Implementing the Dodd-Frank Wall Street Reform and Consumer Protection Act: Letter from CRL and allies with specific recommendations for mortgage and servicing standards, including how to define "qualified residential mortgages."