March 27, 2006 Office of the Comptroller of the Regulation Comments Currency Chief Counsel’s Office 250 E Street, SW Office of Thrift Supervision Public Reference Room 1700 G Street, NW Mail Stop 1-5 Washington, DC 20552 Washington, DC 20219 Attn.: Docket No. 2005-56 Attn.: Docket No. 05-21 Jenifer Johnso Robert E. Feldman Secretary Executive Secretary Board of Governors of the Attn: Comments/Legal ESS Federal Reserve System thFederal Deposit Insurance Corporation 20 St. and Constitution Ave, NW th550 17 Street, NW Washington, DC 20551 Washington, DC 20429 Attn.: Docket No. OP-1246 Mary Rupp Secretary of the Board National Credit Union Administration 1775 Duke Street Alexandria, VA 22314-3428 Re: Proposed Guidance- Interagency Guidance on Nontraditional Mortgage Products 70 FR 77249 (December 29, 2005) Dear Sir or Madam: 1America’s Community Bankers (ACB) appreciates the opportunity to comment on the 2Proposed Guidance – Interagency Guidance on Nontraditional Mortgage Products (“Proposed Guidance”) issued by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of Thrift Supervision and the National Credit Union Administration (collectively, the “Agencies”). 1 America’s Community Bankers is the member driven national trade ...