| January 24, 2006
Office of the Comptroller of the Currency
250 E Street, SW
Public Reference Room
Mail Stop 1-5
Washington, DC 20219
Attn.: Docket No. 05-21
|
Regulation Comments
Chief Counsel’s Office
Office of Thrift Supervision
1700 G Street, NW
Washington, DC 20552
Attn.: Docket No. 2005-56
|
Robert E. Feldman
Executive Secretary
Attn: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
|
Jennifer Johnson
Secretary
Board of Governors of the
Federal Reserve System
20th St. and Constitution Ave, NW
Washington, DC 20551
Attn.: Docket No. OP-1246 |
Re: Proposed Guidance- Interagency Guidance on Nontraditional Mortgage
Products
70 FR 77249 (December 29, 2005)
Dear Sir or Madam:
America’s Community Bankers (ACB) appreciates the opportunity to comment on the
Proposed Guidance – Interagency Guidance on Nontraditional Mortgage Products
(“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”).
ACB urges the Agencies to extend the February 27, 2006 due date for comments on
the Proposed Guidance by 30 days. The proposed guidance was published in the
Federal Register on December 29, 2005. The beginning of the comment period
coincided with the holidays.
The proposal is extremely complex and has far-reaching consequences for our
members, as well as for the nation’s mortgage markets. We believe that it will
take an additional 30 days to complete the necessary evaluation and collect
comments and data from our membership. A 30-day extension would enable our
association to provide the Agencies with the most meaningful comments on the
proposed guidance.
For these reasons, we request that the Agencies extend the comment period on the
proposed guidance to March 29, 2006. We appreciate your consideration of the
requested extension and urge you to make a determination as quickly as possible.
Sincerely,
Janet Frank
Director, Mortgage Finance
Government Relations
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