The PCMA was pleased to provide the Office of the Superintendent of Financial Institutions Canada (“OSFI”) with our comments in connection with Draft Guideline B-20 Residential Mortgage Underwriting Practices and Procedures published July 6, 2017 (the “Draft Guideline”).
We consulted with you, our members, and in particular with our Mortgage Investment Entity (MIE) Committee, who gathered member input and prepared and finalized the comment letter.
The actions included:
· A webinar for PCMA members to provide information and gather feedback and comments;
· Consultation with representatives of the residential mortgage industry who may be affected, including mortgage brokers and non-bank lenders; and
· Review by the PCMA board of directors of this letter.
The letter reflects the comments and input from all those who attended, participated and provided meaningful feedback and comments. The first section of the letter presents our general comments with respect to the Draft Guideline, followed by comments on the specific proposals.
The Comment Letter is available HERE