Letter to CSBS on the Proposed Regulatory Prudential Standards

Dear Sir or Madam:

The American Bankers Association ("ABA") appreciates the opportunity to comment on the recent solicitation issued by the Conference of State Bank Supervisors ("CSBS") regarding proposed regulatory prudential standards for nonbank mortgage servicers. CSBS is requesting public comment on "Proposed Regulatory Prudential Standards for Nonbank Mortgage Servicers" and seeks feedback to help inform state regulators in their ongoing development of a consistent national regulatory structure for nonbank mortgage servicers.

ABA members are critical participants in the national mortgage markets as originators and investors (both in portfolio loans serviced by others and in mortgage-backed securities and similar secondary market investments). On behalf of our customers and shareholders, our members have a vital interest in the effective functioning of primary and secondary mortgage markets, as well as in the stability of our financial system. For all these reasons, ABA strongly supports the efforts of CSBS to develop comprehensive and consistent safety and soundness standards for nonbank mortgage servicers and investors in mortgage servicing. These planned "Baseline Prudential Standards" would promote stronger protections for mortgage borrowers and investors, while also enhancing the stability of our nation's mortgage finance system.

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