Earlier this month, the CFPB put out an updated small entity compliance guide for the ability-to-repay/qualified mortgage rule, incorporating clarifications and amendments to the rules issued on May 29, 2013, and July 10, 2013. The updated guide includes a handful of new sections, one of which goes into some detail about the exemptions that were added by the June 2013 concurrent final rule for certain creditors and loan programs, such as designated community development organizations, certain nonprofit organizations, and...
The CFPB’s ability-to-repay rule and its qualified mortgage standard are getting closer every day, and best practices may provide the surest path to compliance. First off, if you haven’t started, start now. “There’s a lot to do, there’s a lot to know, and there’s a lot to sort out. So, go ahead and get started. It’s already August, and January will be here before we know it,” Ginger Moore, the compliance officer at PrimeLending, a top-25 mortgage originator based in Dallas, TX, told participants during a recent Inside Mortgage...
Tammy Butler, the director of fair lending and compliance for Optimal Blue, a leading pricing engine, said she’s been hearing from one attorney and industry consultant after another that the time of mortgage lenders naming their fees just to re‐name profit is not going to go over well with the CFPB. “In fact, those who have been through the exams or been fined have learned the hard way that complete transparency to the consumer is a must,” Butler said.For instance, Butler has heard some lenders plan on lumping a...
There are plenty of challenges associated with the CFPB’s new standards for error notices and information requests, which are part of the bureau’s new mortgage servicing standards, and policy analysts at PricewaterhouseCoopers have some compliance suggestions to help companies measure up. “The new standards for error notices and information requests are expected to have a substantial impact on all mortgage servicers,” the PwC analysts said in a recent overview. “Implementing the changes will require careful review and possibly...
The CFPB may need to reach out more to consumers in areas that face the highest risk of foreclosure, and intensify pressure on lenders that serve older Americans, according to a new analysis of the CFPB’s consumer complaint database by a handful of faculty members at the Yale University School of Law. Analyzing a new data set of 110,000 consumer complaints lodged with the bureau, they found that Bank of America, Citibank and PNC Bank were “significantly less timely in responding to consumer complaints than the average financial...
Bureau to Evaluate Effect of Bundled Financial Products on Economically Vulnerable Consumers. Earlier this month, the CFPB published a notice and request for comment indicating it plans a data collection and review of bundled financial products and services in order to understand their effects on the financial decision-making of economically vulnerable consumers in the United States, especially as it relates to asset building and financial capability. Comments are invited on whether the collection of information is necessary for...
CFPB examiners found numerous loss mitigation mistakes, including inconsistent communications with borrowers, spotty loss mitigation underwriting and long application review periods. All this could lead to new regulations for servicers.
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