Reverse mortgages are home-secured loans typically offered to elderly consumers. Financial institutions currently provide two types of reverse mortgage products: the lendersâ own proprietary reverse mortgage products and reverse mortgages insured by the Federal Housing Administration (FHA) within the U.S. Department of Housing and Urban Development (HUD). Reverse mortgage loans insured by the FHA are made pursuant to the guidelines and rules established by HUDâs Home Equity Conversion Mortgage (HECM) program. HECM loans and proprietary reverse mortgages are also subject to consumer financial protection laws and regulations (e.g., the regulations that implement laws such as the Real Estate Settlement Procedures Act (RESPA) and the Truth in Lending Act (TILA)).
In August 2010, the Federal Financial Institutions Examination Council (FFIEC), on behalf of its member agencies, published a Federal Register notice adopting supervisory guidance titled âReverse Mortgage Products: Guidance for Managing Compliance and Reputation Risks.â The guidance is designed to assist financial institutions with risk management and efforts to ensure that their reverse mortgage lending practices adequately address consumer compliance and reputation risks. The reverse mortgage guidance discusses the reporting, recordkeeping, and disclosures required by federal laws and regulations and also discusses consumer disclosures that financial institutions typically provide as a standard business practice. Certain portions of the guidance are information collections subject to the Paperwork Reduction Actâs (PRA) requirements.
US Code:
12 USC 248
Name of Law: Federal Reserve Act
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.