HIGHLANDS RANCH, Colo. — Steve Von Sickler, SVP and chief lending officer for Red Rocks Credit Union here, is also chairman of the ACUMA Regulatory Compliance Committee that drafted an extensive response to the NCUA's request for comment on subprime lending. The recently released Interagency Statement on Subprime Mortgage Lending, he said, "included most all of our recommendations." Of particular mention was:
* Underwriting Standards — An institution's analysis of a borrower's repayment capacity should include an evaluation of the borrower's ability to repay the debt by its final maturity at the fully indexed rate, assuming a fully amortizing repayment schedule.
* Consumer Disclosure Issues — The Agencies have determined that, given the growth in the market for the products covered by the Statement and the heightened legal, compliance, and reputation risks associated with these products, guidelines are needed now to ensure that consumers will receive the information they need about the material features of these loans.
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