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FDIC Federal Register Citations

America's Community Bankers

January 24, 2005
Office of the Comptroller of the Currency
Public Reference Room
250 E Street SW
Washington DC 20219
Jennifer J. Johnson, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue NW
Washington DC 20551
Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington DC 20429
Regulation Comments
Chief Counsel's Office
Office of Thrift Supervision
1700 G Street, NW
Washington DC 20552

Re: Proposed Guidance- Interagency Guidance on Nontraditional Mortgage Products 70 FR 77249 (December 29, 2005)

Dear Sir or Madam:

America’s 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 nation’s 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 as possible.


Janet Frank
Director, Mortgage Finance
Government Relations

1America’s 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 70 Fed. Reg. 77249 (December 29, 2005).


Last Updated 01/25/2006

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