What May Be Coming Down The Lending Compliance Pipeline

A look at the CFPB’s Semiannual Regulatory Agenda provides clues to what regulations lie ahead.

 

By CUNA Mutual Group

 

The Consumer Financial Protection Bureau (CFPB) recently celebrated its second birthday, but there are no signs of the CFPB slowing down. Instead, a close look at the CFPB’s recently released Semiannual Regulatory Agenda indicates it is moving full speed ahead on regulatory rule making. The highlights of the CFPB’s agenda provide a few predictions of what compliance officers can expect to hit their desks over the next six months. Let’s take a look.

  • On the Horizon: Changes To Deposit Regulations

The CFPB indicates it will finalize revisions to Regulation CC, which was first proposed by the Federal Reserve, by the end of the year. The new rules will update the Expedited Funds Availability Act for transition to an all-electronic interbank check collection and return process. Although the practical impact to credit union members may be minimal, compliance officers are likely to have to learn new time periods for funds availability and new model form disclosures.

  • Here to Stay: CFPB’s Long-Term Fair Lending Agenda

The CFPB has clear ambitions to expand its regulatory focus. The CFPB’s regulatory agenda unmistakably signals that fair lending will be a focal point of new rule making starting in 2014. The start of this effort will be a hard look at the data gathering requirements under the Home Mortgage Disclosure Act (HMDA) and will later expand into possible rules mandating the collection of credit application data for credit unions involved with business lending. 

  • No End In Sight: Mortgage Rule Changes

In addition to the six rules issued in January, the CFPB indicates it will press forward with issuing the seventh mortgage rule in October. The final rule will create a combined disclosure under Regulation Z and Regulation X. Although the rules already finalized focus on the policies and procedures of underwriting and servicing, the combined disclosure rule will completely revamp the disclosure requirements connected to the loan event, making the end of 2013 a busy time for mortgage lenders.

The CFPB’s regulatory agenda sets the expectation that the furious pace of regulatory change will continue for the coming year. Those of you who were hoping for a reprieve will instead have to keep up with the precocious two-year-old agency.

Jonathan Bundy is a regulatory compliance manager for CUNA Mutual Group in Madison, WI. He can be reached at Jonathan.Bundy@cunamutual.com or (608) 665-7101.Bundy is a featured speaker at the 4th annual Online Discovery Conference on Oct. 1.


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Aug. 19, 2013


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