CFPB Releases 2019 Fall Agenda

Adam Witmer
Regulatory Update

On 11/20/19, the CFPB released their twice-a-year agenda of planned rulemaking activities.  Interesting observations of changes from the spring agenda include the addition of “E-Sign Act Requirements” being added to the long-term actions list while “Regulation E Modernization” was removed from the long-term actions list.  It should also be noted that, while this list outlines their planned agenda, that things can change.  For example…

CFPB Assessment of TRID

Adam Witmer
Regulatory Update, TRID

On 11/20/19, the CFPB announced a request for public comment on an assessment it will conduct on the TRID rules. 

As part of its assessment, the Bureau intends to address TRID’s effectiveness in meeting the purposes and objectives of the Dodd-Frank Act, the specific goals of the rule, and other relevant factors.  The public is invited to comment on the feasibility and effectiveness of the assessment plan, recommendations to improve the assessment plan, and recommendations for modifying, expanding, or eliminating the TRID Rule…

Closing Disclosure NMLS Number for Different MLO

Closing Disclosure NMLS Number for Different MLO

Adam Witmer
Regulation Z, SAFE Act, TRID

In this Compliance Clip (video), Adam explains what NMLS should go on the Closing Disclosure when one lender issued the Loan Estimate, but a different loan officer is now assigned to the loan. This situation can be tricky for financial institutions that don’t have much turnover with their lending staff. Fortunately, Adam busts out some commentary to guide the way on how to comply.

NFIP Set to Expire on November 21

Adam Witmer
Flood

As has been the case over a dozen times in the last few years, the National Flood Insurance Program’s (NFIP’s) short-term extension is set to expire unless Congress either establishes a long-term fix or just kicks the can down the road again by implementing another short-term extension. Either way, financial institutions will once again want to be prepared in the event the NFIP does lapse. The current NFIP extension is set to expire at midnight on Thursday, November 21, 2019. For information on what to do in the event of a lapse, you can…

FDIC Issues CMP For RESPA Section 8 Violation

Adam Witmer
RESPA

On 11/6/19, the FDIC issued a CMP in the amount of $1,350,000 to HomeStreet Bank.  In their release, the FDIC explained that they determined that HomeStreet Bank, through its now discontinued Home Loan Center-based mortgage banking business line, entered into certain co-marketing arrangements in which the bank and real estate brokers agreed to market their services together using online platforms. The FDIC also determined that the bank entered into desk rental agreements whereby…

CFPB Cracks Down on Student Debt Relief Operation

Adam Witmer
Regulatory Update

On 10/30/19, the CFPB announced an action to halt a student-loan debt-relief operation engaged in allegedly unlawful conduct and consisting of several related companies. The Bureau alleges that since at least 2015, the debt-relief companies operated as a common enterprise and deceived thousands of federal-student-loan borrowers and charged over $71 million in unlawful advance fees in connection with the marketing and sale of student-loan debt-relief services to consumers.  

As described in the complaint, the Bureau alleges that…

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