The big news in the compliance world over the holidays is that Barack Obama decided to override the block created by Senate Republicans and appoint Richard Cordray (of Jeopardy fame) as director of the Consumer Financial Protection Bureau. Mr. Cordray’s nomination for director was strategically blocked by Republicans to avoid any one person having too much power (for more on this, read the US Constitution) given the vast reaches of the CFPB.
With the new director in place expect rule making, enforcement and supervision efforts to accelerate as 2012 ramps up. High up on the “To Do” list at the CFPB is the launching of the non-bank supervision program(s). These programs will extend to residential mortgage brokers, lenders, servicers, payday lenders and private student lenders, regardless of size. If you want to be proactive in your compliance & audit plan, you would do well to review the Examination Procedures for Mortgage Originators put out by the CFBP. Those can be found HERE.
The ABA published a list of the top 10 mortgage reforms for 2012. I won’t bore you with intricate details, however be aware that the following will be ‘most likely to change’ in the foreseeable future: