The CFPB’s regulatory priorities for the semiannual period ending October 31, 2014, include continuing work to implement Dodd-Frank Act mortgage protections, a series of rulemakings to address critical issues in other markets for consumer financial products and services, and following up on earlier efforts to streamline and modernize regulations that the CFPB has inherited from other Federal agencies. Implementing Dodd-Frank Act Mortgage Protections A major effort of the CFPB is the implementation of its […]
Category: Dodd-Frank Act
CFPB DIVERSITY ISSUES – LESSONS LEARNED
Recently it has been revealed that the Consumer Financial Protection Bureau (CFPB) has a disparate treatment problem. CFPB managers have rated white staff members distinctly better than minority staff members in staff reviews that are used, in addition to other purposes, for determining raises and bonuses. The evidence against the CFPB appears solid. The manner in which the CFPB has responded to this embarrassing mess holds lessons for any bank subject to charges of disparate […]
IMPLEMENTING THE NEW INTEGRATED DISCLOSURES – Part II
As explained in the first part of this article implementing the new integrated disclosures is a massive task. Lenders that have a plan and get an early start on the process will complete the task by the August 1, 2015 deadline with minimal stress to all involved. We advocate a three-step process for implementing the New disclosures. Master the Material – Mastering 1,888 pages of regulation and related material doesn’t happen quickly. Most of us […]
IMPLEMENTING THE NEW INTEGRATED DISCLOSURES – Part I
The Consumer Financial Protection Bureau (CFPB) published final rules to implement the new integrated disclosures on November 20, 2013. The rules complete the Dodd-Frank mandate to combine the disclosures required by the Truth-in-Lending (TILA) and Real Estate Settlement Procedure Acts (RESPA). The regulations, the Official Interpretations and instructions for completing the forms are massive, covering 1,888 pages. Have you begun the implementation process yet? You have until August 1, 2015 to complete the task, […]
PROPOSED TIL CHANGES – GOOD NEWS?
On April 30 the Consumer Financial Protection Bureau (CFPB) proposed changes to Regulation Z rules related to the small servicer exemption and to the qualified mortgage rules. The proposal is on a fast track, with a 30-day comment period. Small Servicer The proposed changes to the small servicer rules are nice. The CFPB proposes an alternative small servicer definition for nonprofit entities that meet certain requirements, and amend the existing exemption from the ability-to-repay rule […]