Add text here€¦ · 1 CFPB Update May 2014 Marvin Stone CFPB Program Manager . - About the CFPB -...

1

CFPB Update

May 2014

Marvin Stone

CFPB Program Manager

- About the CFPB

- Effective Date

- Loan Estimate

- Closing Disclosure

- Delivery Alternatives

- Three-Day Rule

- All-In APR

- Electronic Storage

- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps

2 © Copyright Stewart 2014

About the CFPB

Banks under a microscope

Mortgage origination

Mortgage servicing

Loss mitigation

Auto loans

Student loans

Service Members Civil Relief Act

Consumer Complaint Database

Remittance

Deposits

Non-Banks now under Federal supervision and enforcement

Audits off the record

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


Response and input on Proposed Rule

Response to Request for Information

eClosing informal Pilot

RFP Partner

ATR/QM feedback

Stewart and the CFPB

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


Disclosures Controls Complaints Transformati

on

1 2 3

Buyer Seller roker Agent Builder Local Lender

4

CFPB Areas of Focus

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


1. Disclosures Effective Date August 1, 2015

Final Rule in November

Forms finalized

Loan Estimate 3 pages

Closing Disclosures 5 pages Lender or Settlement can prepare / deliver

3-Day (Business Day) Rule

Does not remove 3-Day Right of Rescission on refis

$100 tolerance dropped 1/8% Apr instead Like TIL

rekeying?

Requirements for retention but not Standard Format

May still need a disbursement statement

Back to Itemized Fees with totals (GFEExpressQuote)

UCD + HMDA = XRAY

Pilots Beginning January 2015 +/-

New guides released 89 pages

Lenders, Doc Providers & LOS integrations

Itemized fees return

** Personal feedback from two Realtors

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


2. Controls

CFPB Bulletin to Banks and Non-Banks stating they must use quality service providers.

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


ALTA Best Practices Roundtable

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


Best Practices Roundtable Meeting

Regulatory pressures on banks (CFPB, OCC, FDIC)

Title and settlement are most difficult to manage

All lenders present support ALTA Best Practices

-

-

Target for self-assessments by August 1st.

ALTA Best Practices Roundtable

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


ALTA Best Practices

1. Current Licenses - Establish and maintain current

License(s) as required to conduct the business of title

insurance and settlement services.

2. Escrow Accounts - Adopt and maintain appropriate

written procedures and controls for Escrow Trust

Accounts allowing for electronic verification of

reconciliation.

3. Privacy Program- Adopt and maintain a written

privacy and information security program to protect

Non-public Personal Information as required by local,

state and federal law.

4. Settlement Processes - Adopt standard real estate

settlement procedures and policies that help ensure

compliance with Federal and State Consumer Financial

Laws as applicable to the Settlement process.

5. Written Procedures - Adopt and maintain written

procedures related to title policy production, delivery,

reporting and premium remittance.

6. Insurance Coverage - Maintain appropriate

professional liability insurance and fidelity coverage.

7. Complaints Process - Adopt and maintain written

procedures for resolving consumer complaints.

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


ALTA Best Practices

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


Lenders and Consumer Complaints

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


3. Complaints

CFPB Consumer Complaint

Database reaches 300,000.

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


Complaint Response

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


CFPB Exams

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR


- Proposals Not

Adopted

Overview

1. Disclosures

2. Controls

3. Complaints

4. Transformation

Next Steps


Exam or OCC MRA audit where they review consumer complaints and find that our settlement providers have no process for capturing or resolving complaints. It

Bank of America

Title & Settlement Strategy

National Lender on Complaints

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