CHASEO
JPMorgan Chase Bank, N.A.
194 Wood Avenue South
Iselin, New Jersey 08830
August 15,2007
Jennifer J. Johnson
Secretary
Board of Governors of the
Federal Reserve System
20th Street and Constitution Ave., NW
Washington, D.C. 20551
Attn: Docket No. OP-1288
Email :regs. comm ents@federal reserve, gov
Re:
Federal Reserve System Docket No. OP-1288 - Notice of public hearing
and request for comment.
JPMorgan Chase Bank, N.A. ("Chase") appreciates the opportunity to offer
comment and to respond to the specific questions posed by the Board of
Governors of the Federal Reserve System ("Board") at 75 Federal Register 30380
(May 31, 2007), with respect to the exercise of the Board's authority under the
Truth in Lending Act ("TILA") to address certain lending practices. Chase
strongly supports the Board's objective to address concerns regarding certain
mortgage practices while preserving incentives for responsible lenders to provide
mortgages to a wide array of borrowers.
This letter will: (i) set forth important considerations for the Board in the exercise
of its authority under the TILA; (ii) comment on the Board's authority; (iii) offer
recommendations; and (iv) respond to the specific questions asked by the Board.
At Chase, we are committed to helping our customers achieve and, more
importantly, sustain home ownership. Key to our mission is properly evaluating
our borrowers' ability and willingness to repay their mortgage with us. We have
Board of Governors of the Federal Reserve System
August 15,2007
developed five fundamental principles to guide our business practices in home
lending.
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We want our customers to be informed and able to make
responsible choices based on their individual circumstances.
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We want to offer a broad array of mortgage products that address
the financial needs and circumstances of our customers and
provide good value at a competitive price.
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We want to be there if our customers suffer a life event and need
our assistance to remain in their home.