Extension of interagency reverse mortgage guidance proposed by Fed

The Federal Reserve Board is considering a three-year extension of interagency guidance regarding reverse mortgage products and will accept comments from the public until Sept. 4, according to a notice in Tuesday’s Federal Register.

The guidance, Interagency Guidance on Managing Compliance and Reputation Risks for Reverse Mortgage Products, was first adopted in 2010 by all the federal bank, thrift and credit union regulatory agencies under the umbrella of the Federal Financial Institutions Examination Council (FFIEC). That guidance focused on the need to provide adequate information to consumers about reverse mortgage products; to provide qualified independent counseling to consumers considering these products; and to avoid potential conflicts of interest. It also addressed related policies, procedures, internal controls, and third party risk management.

The Fed notes that certain portions of the guidance are “information collections” subject to the PRA’s requirements. The information collection being renewed by the Fed – and without revision – applies to state member banks that originate proprietary reverse mortgages.

As it considers the three-year extension, the Fed is inviting feedback on the following:

  1. Whether the proposed collection of information is necessary for the proper performance of the Federal Reserve’s functions, including whether the information has practical utility;
  2. The accuracy of the Federal Reserve’s estimate of the burden of the proposed information collection, including the validity of the methodology and assumptions used;
  3. Ways to enhance the quality, utility, and clarity of the information to be collected;
  4. Ways to minimize the burden of information collection on respondents, including through the use of automated collection techniques or other forms of information technology; and
  5. Estimates of capital or startup costs and costs of operation, maintenance, and purchase of services to provide information.

Proposed Agency Information Collection Activities; Comment Request