Consumer Financial Protection Bureau Oversight

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As you can clearly see, the number of exceptions has remained relatively low for all compliance categories. The highest number of TIL exceptions was in 2009 and resulted in a total of 65 exceptions for an exception rate of 16 percent. This graphical depiction clearly validates the continued reporting by FCA of System compliance to the FRB/CFPB.
Does the System Need the CFPB?
The three primary reasons the System should be excluded from Consumer Financial Protection Bureau Oversight are as follows:
a) System institutions have not and do not engage in risky behaviors that contributed to the financial crisis of the early 2000s;
b) FCA borrower rights regulations that protect the borrower; and,
c) System institutions have traditionally generated a limited number of consumer loans.
Additionally, a primary factor in the financial crisis was unsustainable mortgage lending. Subprime mortgages increased from eight percent of total mortgages in 2004 to twenty percent in 2006 with more than 90 percent of these mortgages being adjustable rate mortgages allowing borrowers to qualify for loans for which they did not have long-term repayment capacity. Furthermore, lenders lowered their loan underwriting standards especially for loan to appraised value and repayment capacity to allow borrowers to obtain significantly larger loans than in the past. System institutions did not participate in lowered lending standards. The System is prohibited by regulation from making mortgage loans with
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