Evolving State Supervision: Issues Arising From State Qualification Standards and "SAFE" Act Licensing, and Coordination with the CFPB

Troutman Pepper
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In This Presentation:

- Events That Changed Our World; And Yours Too!

- Current Issues in Licensing

- State Coordination With CFPB

- The Path to Coordination

- Responsibilities of the SCC

- Supervision Coordination

- Elements of Coordination

- 2014 Coordinated Exam Schedule

- Multi-State Mortgage Committee

- 2015 Proposed Schedule

- Mortgage Loan Servicing

- Mortgage Due Diligence

- Loss Mitigation Underwriting and QA/QC

- Compliance Reviews

- SAFE (Secure and Fair Enforcement for Mortgage Licensing) Act

- SAFE Act

- State Licensed MLO Under the SAFE Act

- Dodd Frank Act

- CFPB Regulations G and H (76 F.R. 78483, 12/18/11)

- Loan Originator Compensation Requirements under the Truth in Lending Act (12 C.F.R. 1026)

- Hypothetical

- What Happened

- What Happened Led To:

- Change in Market Share between Banks and Non-Depository Servicers

- FSOC Perspective

- The “Capital” Question

- Failure…………is not an option

- Failure… when there are no options

- What Will Make Traditional Resolution, or a Simple Buyout, More Difficult

- Questions & Answers

- Excerpt from Events That Changed Our World; And Yours Too!:

•2008 – Congress passes SAFE Act

-That same year – NMLS was launched

•2010 – Dodd-Frank passes

-That same year – Consumer Access launched

•2011 – CFPB becomes an agency

-That same year, states enter Information Sharing MOU with CFPB

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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