In what seemed to us to be a very long speech for him, Richard Cordray, Director of the Consumer Financial Protection Bureau spoke of three major changes that had affected his audience over the past few years. He spoke to members of the Mortgage Bankers Association (MBA) at their annual convention in San Diego, touching on the qualified mortgage (QM) rule, the recent implementation of the new TILA-RESPA Integrated Disclosure (TRID) rule and forms, and last week release of final rules for reporting under the Home Mortgage Disclosure Act (HMDA). He also elaborated on a recent Bureau bulletin about marketing services agreements (MSAs.) It was his remarks on TRID implementation that pricked up a few ears.

Richard J. Andreano, Jr. a partner in the Ballard Spahr law firm which monitors CFPB activity interpreted Cordray's remarks as a "Warning to vendors" on TRID compliance. Andreano said "He indicated that not only the CFPB but all of the financial regulators might 'need to devote greater attention to the unsatisfactory performance of these vendors and how they are affecting the financial marketplace.' Director Cordray's remarks suggest that the CFPB may be questioning whether various vendors are qualified to provide the services they offer and is preparing to use its supervisory and enforcement authority as to 'servicer providers' to take a closer look. (Under Dodd-Frank, the CFPB can examine "service providers" to entities that it supervises.)"

Related Practices

Mortgage Banking