IMBs are the most regulated segment of the mortgage industry, subject to supervision and enforcement by every state they do business in – and unlike 99% of banks, regulated by the CFPB. Further, unlike all banks, IMBs must meet all SAFE Act requirements. CHLA supports more balanced, uniform regulatory treatment:

HR 1964 [Rep. Williams (R-TX)] – legislation exempting small IMBs (less than $50 million net worth and fewer than 25,000 loans/year) from CFPB exams and enforcement actions.

• Opportunity for small/mid-sized IMBs to correct CFPB compliance problems prior to imposition of fines and enforcement action – similar to how banks and credit unions are regulated.

• SAFE Act Parity. Borrowers should have the same consumer protections whether a mortgage loan is originated by a bank, credit union, or IMB. Mortgage loan originators that work for banks and CUs should be required to pass the SAFE Act test and an independent background check in order to be registered to originate loans, just as all IMB loan originators must now do.