Risk-Based Capital Guidelines; Capital Adequacy Guidelines; Capital Maintenance; Capital-Residential Mortgage Loans Modified Pursuant to the Making Home Affordable Program. [Docket ID: OCC-2009-0007]
1. State the administrative agency which controls the regulation. Explain why this agency and your proposed regulation interests you (briefly). Will this proposed regulation affect you or the business in which you are working? If so, how? Submit a copy of the proposed regulation along with your responses to these five questions. (10 points)
* The administrative agencies that control this regulation are The Office of the Comptroller of the Currency (OCC), Department of the Treasury; Board of Governors of the Federal Reserve System; Federal Deposit Insurance Corporation (FDIC); and Office of Thrift Supervision, Department of the Treasury. * The regulation changed the business in which I worked drastically. I worked as a collection manager of a 10 billion dollar sub-prime mortgage portfolio. Once US Bank signed up for the Making Home Affordable Program in August 2008, it will affect our daily business until the program concludes on December 31, 2012. The program detailed how our financial institution performed Loan Modifications, conducted foreclosures and assigned risk weight to Home Loans.
2. Describe the proposal/change. (10 points)
* The regulation change was proposed as a way to support financial institutions in standardizing and implementing The Making Home Affordable Program. To provide stability to financial institutions with failing home mortgages, help weight credit risk assessment; and additionally to regulate home foreclosures.
3. Write the public comment that you would submit to this proposal. If the proposed regulation deadline has already passed, write the comment you would have submitted. Explain briefly what you wish to accomplish with your comment.(10...