Kicked in the gut by a "flat fee" proposal, the already winded mortgage industry seems to be barely able to catch its breath from the CFPB's recent lurching toward yet another vaguely expected and somewhat ill-defined…more
Can a SAR catch a RAT?
In its just released review of Suspicious Activity Report (SAR) trends, tips, and issues, FinCEN included a brief, but illustrative statement about how a SAR filing eventually led to an indictment…more
The Consumer Financial Protection Bureau (CFPB) will make Fair Lending a focus of its examinations.
I have written extensively on these examinations.
Our firm is committed to providing comprehensive audit and due diligence…more
The CFPB recently announced that it will update the TILA loan originator compensation rule (Rule) in July of 2012. The updated rule may cause some new concerns regarding the implementation of the current Rule or it just may…more
In this article, we will take a brief look at consumer privacy protection updates at the Federal Trade Commission (FTC), the watchdog enforcement agency charged with protecting consumer privacy, issued a sweeping revisions to…more
On March 7, 2012, the Consumer Financial Protection Bureau (CFPB) issued guidance regarding examination procedures pertaining to compliance with the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE Act or…more
On March 12, 2012, the Bureau of Consumer Financial Protection (CFPB) announced proposed amendments to the confidential treatment of information obtained from persons in connection with its exercise of authorities under federal…more
A new era in filing requirements is about to begin. For the first time, the Financial Crimes Enforcement Network, known as “FinCEN,” will require nonbank mortgage lenders and originators to implement an Anti-Money Laundering…more
Recently, I met with several accomplished compliance professionals for lunch. There was considerable discussion about the continuing growth of the regulatory frameworks, the bureaucracies to maintain them, and economic burden on…more
Periodically, we review with you the types of administrative actions taken by HUD's Mortgagee Review Board (MRB).
The review of the MRB's published administrative actions should be considered a teaching moment for all FHA…more
On February 16, 2012, the Consumer Financial Protection Bureau (Bureau or CFPB) launched a new initiative, dubbed the Streamlining Regulations Feedback Web Tool.
According to the Bureau, the tool will enable the public and…more
A critical appraisal requirement deadline approaches!
The requirement went into effect on December 1, 2011. The deadline is March 19, 2012.
On and after March 19, 2012, Fannie Mae and Freddie Mac (GSEs) will mandate…more
Here we go again! A commission. The politician's way of seeming to do something, though really doing nothing, all the while defusing criticism and dispersing risk.
Three years late and stunted politically at its very…more
In this article I provide a brief outline of two key areas where credit risk review and risk management conjoin directly to impact a financial institution’s capability to conduct business and manage a thicket of regulations…more
On January 5, 2012, the Consumer Financial Protection Bureau (CFPB) launched its nonbank supervision program.
This program has the goal of implementing supervisory audits and reviews of nonbanks, such as mortgage loan…more
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