Public Comment, Nontraditional Mortgage Products, The Clearing House

Jeffrey P. Neubert Chief Executive Officer 100 Broad Street New York, NY 10004 Tele 212.613.0103 FAX 212.613.9811 Jeffrey.neubert@theclearinghouse.org March 28, 2006 Office of the Comptroller of the Currency Regulation Comments 250 E Street, NW Chief Counsel’s Office Public Reference Room Office of Thrift Supervision Docket No. 05-21 1700 G Street, NW Mail Stop 1-5 Washington, D.C. 20552 Washington, D.C. 20219 Attn: Docket 2005-56 Robert E. Feldman Jennifer J. Johnson Executive Secretary Secretary Attn: Comments/Legal ESS Board of Governors of the Federal Deposit Insurance Corporation Federal Reserve System th th550 17 Street, NW 20 and Constitution Ave., NW Washington, D.C. 20429 Washington, D.C. 20551 Attn: Docket No. OP-1246 Re: Proposed Guidance − Interagency Guidance on Nontraditional Mortgage Products, 70 Fed. Reg. 77249 (December 29, 2005) (“Proposed Guidance”) Ladies and Gentlemen: The Clearing House Association L.L.C. (“The Clearing House”), an association of 1major commercial banks, appreciates the opportunity to comment on the 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”). Our comments on the Proposed Guidance outline common concerns and suggestions of The Clearing House member banks. 1 The members of The Clearing House are: Bank of ...