CRL NCCOB Comment Jan292007

January 29, 2007 VIA ELECTRONIC MAIL North Carolina Office of the Commissioner of Banks Re: Non-traditional mortgage guidance comment 4309 Mail Service Center Raleigh, NC 27699-4309 comments@nccob.org Re: Center for Responsible Lending comments on North Carolina Office of the Commissioner of Banks’ Proposed Guidance on Non-Traditional Mortgage Product Risks Ladies and Gentlemen: 1The Center for Responsible Lending (CRL) appreciates the opportunity to comment on the Office of the Commissioner of Banks (NCCOB)’s proposed Guidance on Non-Traditional Mortgage Product Risks. General Comments CRL applauds NCCOB for taking this important step to protect North Carolina homeowners from some of the most abusive practices associated with non-traditional mortgage products. By adopting the model guidance drafted by the Conference of State Bank Supervisors (CSBC) and the American Association of Residential Mortgage Regulators (AARMR), NCCOB will join the federal banking regulators, the Office of Housing Enterprise Oversight (OFHEO) and other state bank supervisors in putting a stop to practices that lure borrowers into loan products that appear affordable initially, but are designed with a substantial built-in payment shock and cannot be sustained. Like other federal and state regulators, NCCOB has noted that mortgage lenders have increasingly disregarded traditional underwriting standards and extended loans without adequate ...