Public Comment, Nontraditional Mortgage Products, American Financial Services Assn.

th 919 18 Street, NW Suite 300 Washington, DC 20006 March 28, 2006 By Electronic Mail Office of the Comptroller of the Currency Regulation Comments 250 E Street, SW Currency Chief Counsel’s Office Public Reference Room Office of Thrift Supervision Mail Stop 1-5 1700 G Street, NW Washington, DC 20219 Washington, DC 20552 Attn.: Docket No. 05-21 Attn.: Docket No. 2005-56 Jennifer Johnson Robert E. Feldman Secretary Executive Secretary Board of Governors of the Attn: Comments/Legal ESS Federal Reserve System Federal Deposit Insurance Corporation 20th Street and Constitution Ave., NW 550 17th Street, NW Washington, DC 20551 Washington, DC 20429 Attn.: Docket No. OP-1246 Mary Rupp Secretary of the Board National Credit Union Administration 1775 Duke Street Alexandria, Virginia 22314-3428 Re: Proposed Guidance—Interagency Guidance on Nontraditional Mortgage Products, 70 Fed. Reg. 77249 (December 29, 2005) Ladies and Gentlemen: The American Financial Services Association (“AFSA”) hereby submits this comment letter in regard to the proposed Interagency Guidance on Nontraditional Mortgage Products (the “Guidance”) issued for public comment on December 29, 2005, by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of Thrift Supervision, and the Office of the Comptroller of the Currency (collectively, the “Agencies”). AFSA is the trade association for a wide variety of market-funded ...