dodd frank update

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© 2012 TriNovus, LLC.

DODD FRANK AND THE CONSUMER

FINANCIAL PROTECTION BUREAU

Chicagoland Compliance ConferencePresenter: by Blair Rugh

TriComply from TriNovus: www.trinovus.com

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.


CFPB Announced Goals

• Delete unnecessary regulations• Create consumer understandable

disclosures• Understand issues of community banks


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.


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


Regulations To Come

• Combined RESPA and Reg. Z disclosures• RESPA and Regulation Z mortgage servicing rules

o Forced placed flood insuranceo Requests for information and information managemento 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


My Biggest Concerns

• Fair Lendingo Whole division dedicated to ito Office of Women and Minority Inclusiono New HMDA and CRA reporting rules

• Ability to pay• UDAAP - What was fine yesterday may be

illegal today• CFPB effect on other agencies


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

THANK YOU!

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dodd frank update

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