On December 16, 2009, the OCC, FDIC,
FRB and NCUA sought comment on the guidance, and they issued it in
final form on August 17, 2010. The 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. Prior to the effective
date of the final guidance, the Agencies obtained PRA approval from
OMB for the information collection requirements contained therein.
These information collection requirements included implementation
of policies and procedures, training, and program maintenance. The
requirements are outlined below: • Institutions offering reverse
mortgages should have written policies and procedures that prohibit
the practice of directing a consumer to a particular counseling
agency or contacting a counselor on the consumer's behalf. •
Policies should be clear so that originators do not have an
inappropriate incentive to sell other products that appear linked
to the granting of a mortgage. • Legal and compliance reviews
should include oversight of compensation programs so that lending
personnel are not improperly encouraged to direct consumers to
particular products. • Training should be designed so that relevant
lending personnel are able to convey information to consumers about
product terms and risks in a timely, accurate, and balanced
manner.
US Code:
12
USC 1828(o) Name of Law: Federal Deposit Insurance Act
US Code: 12
USC 1819(a) Name of Law: Federal Deposit Insurance 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.