Has Fair Lending Been Neutered?

By: Tammy Butler, Master CMB Fair Lending Perspectives-The CFPB’s Latest Decision If you have anything to do with Fair Lending in your company, you have no doubt heard the news about the recent change at the CFPB with regard to Mulvaney’s decision to strip the Fair Lending Office of enforcement duties and move those duties [...]

2018-06-01T13:09:18-05:00February 8th, 2018|

CFPB- It’s Just Compliance Training-Who Cares?

Rule Synopsis: “It’s Just Compliance Training, who cares? We just have to show our examiners that we checked off a box and that people were trained to satisfy regulatory requirements.” Without retaining the source, I write down interesting statements like the one above, when I am shocked or perplexed by the view. Sadly, I hear [...]

2017-12-26T13:06:35-05:00December 26th, 2017|

CFPB Warns Financial Institutions about Potential Mortgage Lending Reporting Failures

Rule Synopsis: On October 27, 2016 Richard Cordray, the Director of the CFPB, issued a stark warning to lenders who did not file their HMDA data. Many smaller lenders were the ones who were warned, and we have attached a sample letter below for your reference. Interpretive CommentsTo help our subscribers decide if they are [...]

2018-10-27T22:05:26-05:00November 4th, 2017|

CFPB and Mystery Shopping Techniques – Part Three

Rule Synopsis: Protocols for Testing Consistency is key for any testing protocol. This means that a lot of time has to be spent with those who will be doing the testing so that they are equipped to handle any situation. Here are the five basic steps that are followed, once the mystery shopper has completed [...]

2017-12-27T12:19:39-05:00November 3rd, 2017|

CFPB – Mystery Shopping Techniques-Part Two

Rule Synopsis: Those who mystery shop your originators are carefully selected due to the complexity of the mortgage process. The profiles need to be carefully constructed for the data to be of use to the regulatory bodies. This article is Part Two of this series. Part One can be found in our October 2016 issue [...]

2017-12-27T12:22:05-05:00November 3rd, 2017|