The document summarizes a presentation about the Consumer Financial Protection Bureau (CFPB). It notes that the CFPB has exclusive rulemaking authority and its main objective is to protect consumers from unfair practices. It outlines some of the CFPB's announced goals like simplifying disclosures and understanding community banks. It also lists some of the CFPB's major divisions and upcoming regulations. The presenter expresses concerns about the CFPB's focus on fair lending and ability-to-pay rules, and how practices deemed fine today could be illegal under new CFPB rules. Suggestions are given to prepare for the CFPB's impact.
2. Consumer Financial
Protection Bureau
• It answers to no one.
• Exclusive and unlimited rule making authority.
• Principal Objective - To protect consumers from
unfair, deceptive and abusive acts and practices
by financial institutions.
TriComply from TriNovus: www.trinovus.com
3. CFPB Announced Goals
• Delete unnecessary regulations
• Create consumer understandable disclosures
• Understand issues of community banks
TriComply from TriNovus: www.trinovus.com
4. The CFPB: What We
Know By Now
• When complete, will have a staff of 2000 and an
annual budget of $600,000,000.
• It doesn't understand banking.
• It is verbose.
• It’s consumer bias is overwhelming.
• The CFPB is not your friend.
TriComply from TriNovus: www.trinovus.com
5. CFPB Significant
Divisions
• Office of Women and Minority Inclusion
• Office of Fair Lending
• Office of Service Members Affairs
• Office of Financial Protection for Older
Americans
TriComply from TriNovus: www.trinovus.com
6. Regulations To Come
• Combined RESPA and Reg. Z disclosures
• RESPA and Regulation Z mortgage servicing rules
o Forced placed flood insurance
o Requests for information and information management
o Early intervention – loan mitigation
• Zero/zero alternate loan
• MLO Compensation
• Expanded HMDA reporting - up to eleven new data elements
• HMDA like reporting for CRA
• Ability to pay
• New appraisal rules
TriComply from TriNovus: www.trinovus.com
7. My Biggest Concerns
• Fair Lending
o Whole division dedicated to it
o Office of Women and Minority Inclusion
o New HMDA and CRA reporting rules
• Ability to pay
• UDAAP - What was fine yesterday may be illegal
today
• CFPB effect on other agencies
TriComply from TriNovus: www.trinovus.com
8. Suggestions
• Get a good pair of reading glasses
• Don't overreact to proposed regulations
• Get your fair lending house in order
• Don't lose your sense of humor
TriComply from TriNovus: www.trinovus.com