Oct 28

Recent Compliance Issues: 10/2/15 – 10/15/15

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1.  The Consumer Financial Protection Bureau (CFPB) issued a bulletin on Thursday October 8, 2015 providing guidance to the mortgage industry regarding marketing services agreements. The bulletin offers an overview of the federal prohibition on mortgage kickbacks and referral fees, and describes examples from the Bureau’s enforcement experience as well as the risks faced by lenders entering into these agreements. During the course of supervising mortgage lenders and enforcing federal law, the Bureau has found that marketing services agreements carry legal and regulatory risk for lenders. Before the CFPB arrives to review your mortgage lending activities, let our former Federal regulators review your policies and practices in this area to ensure that they are examination-ready.

2.  On October 15, 2015, the Consumer Financial Protection Bureau (CFPB) issued its final rule updating the reporting requirements of the Home Mortgage Disclosure Act (HMDA) regulation. The Bureau is working with other federal agencies to streamline the reporting process for financial institutions. HMDA has been and with the added data fields become even more of a focus of regulators examination efforts. Let our former Federal regulators review your current HMDA collection and reporting procedures and help you prepare for the revised regulation.