"Chairman Dodd, his staff and the Democratic members of his committee clearly put a lot of serious thought and time into this proposal, and we very much appreciate the complexity of the issues and the comprehensiveness of the draft bill.

"MBA supports improved federal oversight of independent, non-depository mortgage lenders, and thus we are interested in the proposal to create a Financial Institutions Regulatory Administration.  MBA believes this could offer consistent uniform regulation to all lenders and brokers.  We recognize, however, the challenges such a regulatory structure would bring and understand that there are some agencies that may not warrant inclusion in such a new regulator.

 "We regret, however, that the bill does not provide for a uniform national standard to protect all consumers consistently, regardless of where they live.  Instead, the proposal would continue the patchwork of state and local lending laws and regulations that cause confusion and allow bad actors to prey on vulnerable borrowers. 

 "We are also concerned with the broad 'skin in the game' provisions included in this proposal that would put certain business models at risk.  These regulations would thus unnecessarily deprive consumers and businesses of competition for safe and sustainable mortgage options and reduce the available funds for home financing by billions of dollars. 

"On a final note, rating agency regulatory reform should strike the delicate balance of providing a robust regulatory framework that avoids stifling the introduction of new and innovative commercial and residential mortgaged-backed security products. MBA will work with Senator Dodd to achieve this appropriate balance.

"We are committed to working with Chairman Dodd and others during consideration of the bill to help make sure that it best serves its intended purpose - ensuring more effective regulation of the mortgage industry and better protection for consumers."      

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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 2,200 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. For additional information, visit MBA's Web site:  www.mortgagebankers.org.