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Compliance Report for SMBA

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:

  1. RESPA-TILA Reforms (combining the two)
  2. “Ability to Repay” and “Qualified Mortgages” (further defining of each)
  3. Risk Retention (institutional requirements and oversight)
  4. Servicing Rules & Requirements
  5. Appraisal Reforms (yes…more of them)
  6. Loan Originator Compensation (clearing up confusion over their “Crystal Clear Rule”)
  7. GSE Reform
  8. CFPB at full capacity and running like a freight train
  9. Fair Lending (This will have a significant impact on all of us come examination time)
  10. Credit Standard revisions (we’ll see the next chapter this year)

 

Stay tuned for a whirlwind of changes this year. 


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February 28, 2012
SMBA Dinner Meeting featuring Elizabeth Bowman, President and Organizing and Productivity Expert at Innovatively Organized

March 1, 2012
Income Property Lunch
Eastside: Update and Analysis Panel
 
Seattle Mortgage Bankers Association | 6351 Seaview Ave NW, Seattle, WA 98107 | Phone: 206.622.8425 | FAX: 206.623.4474 | Email: smba@qwestoffice.net