Americas Community Bankers (ACB)1 appreciates the opportunity to comment
on the Proposed Guidance Interagency Guidance on Nontraditional Mortgage
Products (Proposed Guidance) issued by the Office of the Comptroller of
the Currency, the Board of Governors of the Federal Reserve System, the
Federal Deposit Insurance Corporation, and the Office of Thrift Supervision
(collectively, the Agencies).
ACB urges the Agencies to extend the February 27, 2006 due date for
comments on the Proposed Guidance by 30 days. The proposed guidance was
published in the Federal Register on December 29, 2005. The beginning of the
comment period coincided with the holidays.
The proposal is extremely complex and has far-reaching consequences for
our members, as well as for the nations mortgage markets. We believe that
it will take an additional 30 days to complete the necessary evaluation and
collect comments and data from our membership. A 30-day extension would
enable our association to provide the Agencies with the most meaningful
comments on the proposed guidance.
For these reasons, we request that the Agencies extend the comment period
on the proposed guidance to March 29, 2006. We appreciate your consideration
of the requested extension and urge you to make a determination as quickly
Director, Mortgage Finance
1Americas Community Bankers is the member driven national trade
association representing community banks that pursue progressive,
entrepreneurial and service-oriented strategies to benefit their customers
and communities. To learn more about ACB, visit
www.AmericasCommunityBankers.com. 70 Fed. Reg. 77249 (December 29, 2005).