Add text here - Stewart€¦ · 1 CFPB Update May 2014 Marvin Stone CFPB Program Manager . - About...
Transcript of Add text here - Stewart€¦ · 1 CFPB Update May 2014 Marvin Stone CFPB Program Manager . - About...
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CFPB Update
May 2014
Marvin Stone
CFPB Program Manager
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- 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
Servicemembers Civil Relief Act
Consumer Complaint Database
Remittance
Deposits
Non-Banks now under Federal supervision and enforcement
Audits off the record
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- 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
3 © Copyright Stewart 2014
On Main Street
Response and input on Proposed Rule
Response to Request for Information
eClosing informal Pilot
RFP Partner
On Wall Street
ATR/QM guidance
Stewart and the CFPB
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- 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
4 © Copyright Stewart 2014
Disclosures Controls Complaints Transformation
1 2 3
Buyer Seller roker Agent Builder Local Lender
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CFPB Areas of Focus
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- 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
5 © Copyright Stewart 2014
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
Fee engines renamed and itemized
** Personal feedback from two Realtors
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- 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
6 © Copyright Stewart 2014
2. Controls
CFPB Bulletin to Banks and Non-Banks stating they must use quality service providers.
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- 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
7 © Copyright Stewart 2014
ALTA Best Practices Roundtable
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- 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
8 © Copyright Stewart 2014
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
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Target for self-assessments by August 1st.
ALTA Best Practices Roundtable
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- 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
9 © Copyright Stewart 2014
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.
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- 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
10 © Copyright Stewart 2014
ALTA Best Practices
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- 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
11 © Copyright Stewart 2014
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- 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
12 © Copyright Stewart 2014
Your Policies, Procedures and Internal Controls
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- 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
13 © Copyright Stewart 2014
3. Complaints
CFPB Consumer Complaint
Database reaches 300,000.
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- 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
14 © Copyright Stewart 2014
Lenders and Consumer Complaints
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- 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
15 © Copyright Stewart 2014
Complaint Response
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- 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
16 © Copyright Stewart 2014
CFPB Exams
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- 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
17 © Copyright Stewart 2014
CFPB Exams
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- 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
18 © Copyright Stewart 2014
CFPB Exams