MADISON, Wis. (10/3/13)--Credit union compliance staff need to be aware of the Consumer Financial Protection Bureau's (CFPB) quickly approaching deadlines as 2013 concludes, attendees of CUNA Mutual Group's fourth annual Online Discovery Conference were told by the company's Lauren Capitini and Jon Bundy.
"A look at the CFPB's semiannual regulatory agenda indicates the agency is moving full speed ahead on additional rulemaking," said Bundy, CUNA Mutual regulatory compliance manager. "From this report, we're able to predict what credit union compliance officers can expect to hit their desks over the next six months."
"Right now, credit unions should be focused on implementing changes to comply with the CFPB's [seven] new mortgage rules issued in January," said Capitini, CUNA Mutual regulatory compliance manager, during her "Mortgage Myth Busters" session, which tackled myths about new mortgage regulations. "The mandatory compliance dates for most of these new rules are in January, so credit unions really need to be putting the pedal to the metal."
The CFPB continuously made updates to the seven new mortgage rules over the summer, and only recently finalized the rules. Final updates to the rules include:
- Clarifying the flexibility available to credit unions when dealing with delinquent borrowers;
- Finalizing the rule prohibiting the financing of credit insurance premiums for some types of mortgage loans; and
- Changing the effective date for the loan originator compensation rule to Jan. 1, 2014.
Capitini reminded audience members that other rules outside of the mortgage arena are also quickly approaching, including new remittance transfer rules which go into effect Oct. 28.
Also, an additional mortgage rule to combine the mortgage disclosures under Regulation Z (TILA) and Regulation X (RESPA) is expected from the CFPB later this month, Capitini said. "This [additional] mortgage rule will completely revamp the disclosure requirements connected to the loan event, making the end of 2013 a busy time for mortgage lenders," said Capitini.
Bundy's session, "Lending Compliance Pipeline: What May Be Coming," focused on the CFPB's radar and looking ahead to 2014.
"We anticipate the CFPB will modernize deposit regulations by the end of 2013," said Bundy. "Members may not see much of a practical change from the new rules; however, credit unions will likely have to learn new time periods for funds availability and new model disclosures."
The CFPB could do so by finalizing revisions to Regulation CC, the Expedited Funds Availability Act's implementing regulation, to accommodate an all-electronic interbank check collection and return process by the end of 2013, Bundy explained.
"Looking ahead to 2014, credit unions can expect to see the CFPB expand its fair lending focus," said Bundy. "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 and will later expand into possible rules mandating the collection of credit application data for credit unions involved with business lending, Bundy said.
Other potential regulatory changes on the CFPB's radar include:
- Possible revised disclosures for student loans and credit cards;
- Payday lending and payday alternative loans; and
- Overdraft protection.
Online Discovery is an annual conference sponsored by CUNA Mutual Group that attracts a national and international credit union audience of more than 1,300.