Compliance Blog

Written by Steve Van Beek

The CFPB has been working on mortgage issues in a couple of different areas and I thought it would be a good idea to include links to their information in one location.  Especially as issues seem to disappear on the CFPB's website.  It is truly amazing that a 21st century agency has not included a search bar on either the first or second design of their website.  

I hope the CFPB realizes that institutions cannot instantaneously track and review the hundreds of pages of information the CFPB releases each week.  A search bar would be the first step in increasing transparency.  It really isn't that hard.  The NAFCU Compliance Blog has one.  

***

Mortgage Origination.  The CFPB plans to propose these rules this summer with a final rule in place by January 2013.  Below are links to the CFPB's working documents.

• CFPB's Press Release on Mortgage Origination Rules
• The CFPB's 37-Page Outline of Proposals Under Consideration and Alternatives Considered
• Discussion Issues for the CFPB's Small Business Review Panel

***

Mortgage Servicing.  Just over a month ago, the CFPB released its game plan for Mortgage Servicing.  For these rules, the CFPB plans to have proposals out this summer and a final rule in place by January 2013 (seeing a trend yet?) 

• CFPB's Press Release on Mortgage Servicing Rules 
• CFPB's Fact Sheet on Mortgage Servicing
• The CFPB's 60-Page Outline of Proposals Under Consideration and Alternatives Considered
• Discussion Issues for the CFPB's Small Business Review Panel
• CFPB's Blog Post on its Prototype Mortgage Periodic Statement

According to the CFPB's press release, the CFPB can provide up to one year of implementation time (January 2014).  However, the CFPB hasn't decided on the implementation period.  Credit unions will want to be very clear in their future comment letters about how long this massive overhaul will take and why even the one-year period might not be enough.  

***

TILA/RESPA Disclosures.  The CFPB is also moving forward with their TILA/RESPA mortgage disclosure consolidation.  This was the CFPB's first "Know Before You Owe" campaign.  At this point, it looks like the CFPB is hunkering down with all of their comments with an aim of getting a proposed rule out by July 21, 2012.  

• The CFPB's Blog Post with the Latest Model Forms and the CFPB's Press Release
• The CFPB's 42-Page Outline of Proposals Under Consideration and Alternatives Considered
• Discussion Issues for the CFPB's Small Business Review Panel

***

And, this isn't all of it.  The CFPB will be pretty much changing every aspect of mortgage lending within the next couple of years.  For an eye to what else the CFPB is working on, take a look at their Agency Rule List.  

If the outlines are 37; 60 and 42 pages - how long will the actual rulemakings be??