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Inside the CFPB
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Service Members May be Getting Gouged on Rates, Fees: CFPB

January 12, 2015
Loopholes in the current Military Lending Act rules are allowing lenders to offer high-cost consumer loans to military families by skirting the 36 percent rate cap – in some cases, charging more than 300 percent – as well as sticking them with excessive fees for the products they use, according to recent comments and a report by the CFPB. The MLA is implemented by the Department of Defense, and is enforced by the bureau and other federal regulators. The CFPB filed a comment letter in support of the DOD’s recent proposal to broaden the scope of the MLA rules to cover deposit advance products, and more types of payday, auto title and installment loans. Currently, the MLA rules provide service members and ...
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Plenty of Investigations Underway At the Bureau, Report Suggests

January 12, 2015
The CFPB’s second report to the appropriations committees of both the U.S. Senate and the House of Representatives suggests the bureau has a full plate when it comes to enforcement-related probes of financial services providers. For instance, “Investigations currently underway span the full breadth of the bureau’s enforcement jurisdiction,” the report stated. “Further detail about ongoing investigations will not generally be made public by the bureau until a public enforcement action is filed.” Elsewhere, the report reminded lawmakers that the bureau was a party in 41 public enforcement actions from Oct. 1, 2013, through Sept. 30, 2014, the period covered by the report, and it proceeded to highlight all of them.However, not all of them have been settled, such ...
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CFPB Workforce Report Skips Controversy Over Discrimination

January 12, 2015
The CFPB’s fourth annual human capital report touted the progress the bureau has made in bolstering its human resources capabilities. But it had nothing to say about the controversy over allegations of discrimination and retaliation towards some of its own staff that emerged last year and lead to congressional hearings and a last-minute scramble to adjust the paychecks of select personnel. The closest the bureau got to that issue was a brief mention of requiring a two-day employment civil rights training session for all managers and supervisors, as part of broader effort at leadership development and succession planning. The CFPB also briefly discussed the efforts it is making to attract and retain a diverse workforce. The bureau’s report indicated that ...
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OIG Finds Varying Risk in CFPB Travel, Purchase Card Programs

January 12, 2015
The risk of illegal, improper or erroneous use in the CFPB’s purchase card program is low and the risk level for the agency’s travel card program is medium, according to a recent assessment by the bureau’s Office of Inspector General. “As a result, we will include an audit of the travel card program in the OIG’s 2015 annual audit plan, and we will not include an audit of the purchase card program in that plan,” said the OIG in a new report. “Nevertheless, the Office of Procurement and the Travel Office should continue to take appropriate actions to ensure proper oversight of their respective programs.” The OIG conducted the risk assessment of the programs to determine the frequency and scope ...
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Worth Noting

January 12, 2015
TRID Projected to Cost $527 Million a Year. A new analysis of the costs of government regulation by Sam Batkins, director of regulatory policy at the center-right American Action Forum, estimates that the integrated mortgage disclosure rule promulgated last year by the CFPB will cost the industry $527 million annually. The TILA/RESPA integrated disclosure rule – or “TRID” – is scheduled to take effect Aug. 1, 2015, unless the mortgage industry can convince the CFPB to provide a delay. Elsewhere, Batkins projects compliance with all of the bureau’s 2014 regulations to cost the financial services industry $2.1 billion. All of the CFPB’s regulations since its inception in 2011 are estimated to cost $3.6 billion and 38.9 million hours to comply with. Of ...
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Bureau Minutiae/Vendor/Compliance News/Looking Ahead

January 12, 2015
CFPB Raises TILA Reg Z Exemption Threshold. The CFPB raised the asset size for banks exempt from the requirement to establish an escrow account for higher-priced mortgages under Regulation Z (Truth in Lending Act) from $2.028 billion to $2.060 billion, as of Jan. 1, 2015. The adjustment is based on the 1.1 percent increase in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) for the 12-month period ending in November 2014. The adjustment to the escrow exemption asset-size threshold will also increase a similar threshold for small-creditor portfolio and balloon-payment qualified mortgages. CFPB Increases HMDA Reg C Exemption Threshold. The bureau slightly ratcheted up the asset- size exemption threshold for financial institutions reporting ...
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New, Lower VA Loan Limits: Don’t Sweat It

January 11, 2015
George Brooks
However, the VA loan program does not require a downpayment, which is a major attraction for some borrowers.
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Originators, Realtors Want Clarifications on Escrowing for Flood Insurance

January 9, 2015
George Brooks
The proposed inter-agency rule covers only flood-insurance premium escrows and detached structures.
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Okay, Mortgage Underwriting Has Loosened, But Loan Performance a Concern

January 9, 2015
Brandon Ivey
The average credit score on the 10th percentile of purchase mortgages increased from 555 in 2000 to 655 at the end of the third quarter of 2014.
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SEC Finds Numerous Problems at Rating Services, Suggests Compliance is Improving

January 9, 2015
The Securities and Exchange Commission uncovered a number of compliance issues at the credit rating services in 2013, according to a report released by the federal regulator at the end of December. However, compliance is improving compared with previous exams conducted by the SEC. In exams covering rating activity in 2013, the SEC found issues ranging from conflicts of interest to adherence to policies for reviewing credit ratings to the use of affiliates or third-party contractors. The SEC didn’t single out any of the rating services other than to note whether an issue occurred at one of the big three rating firms or at one of several smaller rating services. For example, the SEC said...
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