For financial institutions and mortgage companies grappling with an array of new rules and procedures promulgated in 2013 by the Consumer Financial Protection Bureau, an update to the mortgage exam procedures is now available. These procedures are what the CFPB says it will be looking for as the new mortgage regulations become effective in January 2014.
According to the CFPB, the newest updates cover the Ability-to-Repay/Qualified Mortgages, high-cost mortgages, appraisals for higher-priced mortgage loans, and new amendments related to the escrows rule. Additionally, the updates include changes to credit card rules. All CFPB mortgage origination rules issues through the end of May 2013 and all mortgage servicing rules issues through July 10, 2013 are included in the updated CFPB mortgage examination manual.
Prior postings on this blog have examined the new rules and what financial institutions need to review and assess in order to be compliant with the CFPB mortgage regulations at the beginning of 2014. The updated examination manuals are helpful in explaining how concepts and issues in the new regulations are defined by examiners. These documents allow financial institutions’ compliance departments to identify problems with current procedures and chart a strong course of compliance as mandated by the new regulations. The examination procedures contain citations to many relevant rules and provide explanations that industry professionals will find relatively straightforward.
Financial institutions issuing mortgages should look at this important tool and use the updated mortgage examination manuals to achieve compliance by the January 2014 deadline. Contact Spilman or other knowledgeable counsel to discuss any questions or for a review of your business’s policies and procedures.