Public Comment, Subprime Mortgage Lending, Iowa Bankers Assn.

May 7, 2007 Public Information Room Jennifer J. Johnson, Secretary Office of the Comptroller of the Currency Board of Governors, Federal Reserve th250 E Street, SW., Mailstop 1-5 20 Street & Constitution Ave, NW Washington, DC 20219 Washington, DC 20551 Attn: Docket #2007-005 Docket No. OP-1278 Robert E. Feldman, Executive Secretary Regulation Comments Federal Deposit Insurance Corp. Chief Counsel’s Office th550 17 Street, NW. Office of Thrift Supervision Washington, DC 20429 1700 G. Street, NW. Washington, DC 20552 No. 2007-09 Ladies and Gentlemen: Iowa Bankers Association (IBA) is a trade association representing nearly 95% of 400+ banks and savings associations in the State of Iowa. We appreciate this opportunity to comment on the Proposed Statement on Subprime Mortgage Lending. We applaud the agencies’ efforts to curb unscrupulous subprime mortgage lending and reduce the current increasing foreclosure rates. It is important to note however, that not all subprime lending is predatory and it does serve a need in fulfilling the American home ownership dream. More and more frequently the IBA receives reports from member banks of instances in which their customers have defaulted on mortgage loans obtained from mortgage brokers or non-bank mortgage lenders that are not supervised by the federal banking agencies. The customers have returned to their local community bank for help in saving their homes from foreclosure. Many ...