ICBA and the other organizations noted that because community banks conduct their business based on firsthand knowledge of their customers and communities, they have every incentive to make fair, safe and affordable loans. Further, community banks have a vested interest in the performance of loans that are held in portfolio, which is why the
"Community banks operate under a completely different business model than that of the larger financial institutions and mortgage companies," the coalition wrote. "Additional underwriting and escrow requirements only function as unnecessary regulatory burdens that stifle community banks' ability to provide solid loan products to consumers so they can achieve the American dream of home ownership."
To qualify for the small-creditor exception under the
In their letter to the
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