In a Request for Information (RFI) posted on the Federal Business Opportunity website last month, the CFPB solicited information from vendors so the CFPB can “better understand current, state-of-the-art capabilities and strategies to aid its consideration on whether to propose a registration system for nonbank financial institutions.”  Pursuant to Dodd-Frank Section 1022, the CFPB is authorized to “prescribe rules regarding registration requirements applicable to a covered person, other than an insured depository institution, insured credit union, or related person.” … Continue Reading

The CFPB has issued a report that discusses the results of a focus group study it conducted on reverse mortgage advertisements and a consumer advisory about such advertisements.

The report is entitled “A close look at reverse mortgage advertisements and consumer risks.”  In conducting its study, the CFPB interviewed 59 homeowners age 62 and older in focus groups and in one-on-one interviews in Chicago, Los Angeles, and Washington, D.C.  … Continue Reading

Please join us in offering well wishes to Karen Morgan, a Mortgage Banking Group associate in the Washington, D.C., office who is leaving Ballard Spahr for a new opportunity at the Consumer Financial Protection Bureau. Karen will be Attorney-Advisor in the CFPB’s Office of Supervision Policy under its Division of Supervision, Enforcement, and Fair Lending.… Continue Reading

Although its new mortgage servicing rules are not effective until January 10, 2014, the CFPB seems to already be using those rules as guideposts in its examinations of servicers.  In its Summer 2013 Supervisory Highlights, which highlights supervision work completed between November 2012 and June 2013, the CFPB focuses on deficiencies in mortgage servicing at both banks and nonbanks. … Continue Reading

The American Association of Residential Mortgage Regulators (AARMR), the trade association for regulators responsible for supervising non-depository mortgage companies, held its annual conference last week in Denver. Not surprisingly, the agenda was heavily focused on the CFPB, and several CFPB officials were in attendance. Unfortunately, the officials, knowingly or not, adhered to the CFPB’s (unofficial?)… Continue Reading

The CFPB has issued guidance that provides states may use the Uniform State Test (UST) developed by the Nationwide Mortgage Licensing System and Registry (NMLSR) to satisfy the testing requirement of the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE Act).   

The SAFE Act requires state-licensed mortgage loan originators to pass a “qualified written test” developed by the NMLSR. … Continue Reading

The CFPB announced earlier this week that it has established a “framework” with the Conference of State Bank Supervisors (CSBS)  for coordination among the CFPB and state regulators on supervision and enforcement matters.  The framework states that it is “intended to establish a process for coordinated federal/state consumer protection supervision and enforcement of entities providing consumer products or services that are subject to concurrent jurisdiction of the CFPB and one or more [state financial regulatory authorities].” … Continue Reading

Last week, the CFPB issued a Statement of Intent that describes its plans for sharing information about nonbanks with state banking and financial service regulators (“State Regulators”)  and coordinating supervisory and enforcement activity.  In January 2011, the CFPB entered into a memorandum of understanding (MOU) with the Conference of State Bank Supervisors (CSBS) and various State Regulators to establish a general framework for information sharing and supervision and enforcement cooperation. … Continue Reading

The CFPB has announced that it has begun development of a National Mortgage Database jointly with the Federal Housing Finance Agency.  The agencies plan to build the database by matching a nationwide sampling of credit bureau files on mortgage loans and payment histories with HMDA data, property valuation models, and other data files.   … Continue Reading

The CFPB’s focus on mortgage reform is again in the spotlight with the CFPB’s announcement yesterday of some of its plans for implementing the residential mortgage loan originator compensation provisions in Title XIV of the Dodd-Frank Act.  The CFPB announced that it intends to propose origination standards this summer, with a goal of adopting final rules in January 2013.
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