June 28, 2012 IBAT filed a comment letter with the CFPB on the proposed rule
to Implement Ability to Repay Mortgage Standards. The letter reiterates points
made in similar comment letters filed in 2011 with the Federal Reserve. IBAT
continues to stress that the availability of credit in numerous communities is
adversely affected by the escrow requirements imposed on "higher-priced
mortgage loans" and any ambiguous "presumption of compliance"
with the ability to repay requirements will continue to erode the availability
of credit in those communities.