Bank Insurance Agency Management
Community Banks and Insurance
Compliance and Risk Management
Wealth Management
Insurance Product Marketing

Tuesday, October 6, 2015

CFPB Advises Industry on Mortgage Disclosure Rule Compliance

By ABIA Outside Counsel, McIntyre & Lemon, PLLC

The CFPB sent a letter to mortgage industry trade groups regarding the Know Before You Owe mortgage disclosure rule

The rule, also known as the TILA-RESPA Disclosure rule—which requires disclosure forms that are easier to use and clearly present terms of mortgage to a borrower— went into effect on October 3.

The letter notes that in preparation to adjust to the requirements of the rule, the mortgage industry has had to make significant systems and operational changes involving coordination with third parties for implementation. The mortgage industry has allocated resources for these purposes and toward understanding the requirements, training affected personnel and addressing technical issues and other questions that will arise when the new forms are in use.

According to the CFPB’s press release, initial compliance examinations will evaluate an institution’s compliance management system and efforts to come into compliance in a timely manner, taking into consideration the scope and scale of changes essential to achieving effective compliance. Examiners will consider the institution’s implementation plan including policy, procedure and process updates, training relevant staff, and its ability to resolve early technical problems and other challenges related to implementation.

The Bureau took a similar approach in initial examinations for compliance with the mortgage rules that became effective at the beginning of January 2014 and found that institutions made good faith efforts to comply and were typically successful in their implementation.

Read CFPB Press Release.

Cybersecurity Remains Top Challenge for CFPB, Fed

Maintaining effective information security programs -- and overseeing cybersecurity at supervised institutions, in the case of the Fed -- remain top management challenges for the Consumer Financial Protection Bureau and the Federal Reserve Board, according to reports released yesterday by the agencies’ inspector general.

The CFPB should focus on overseeing the security of systems operated by contractors and ensuring that personally identifiable information in its possession is protected, the report said. The report cited a Government Accountability Office audit in 2014 that found that “the CFPB has collected consumer financial data on credit card accounts, mortgage loans, and other products” but “that the CFPB lacks written procedures and comprehensive documentation for a number of processes, including data intake and information security risk assessments.”

Both agencies were also urged to address workforce development and retention issues, strengthen their controls over management operations and maintain physical infrastructure properly.

Read the report on the CFPB.

Read the report on the FED.

Monday, October 5, 2015

Agencies to Host Flood Insurance Webinar

On Oct. 22 at 12:30 p.m. EDT, the federal banking agencies will host a free webinar on recent updates to the interagency flood insurance regulations. Topics will include escrowing of flood insurance premiums and fees, lender-placed flood policies and the detached structures exemption.

Register now for the webinar.

Supervisory Expectations for Financial Institutions Implementing the TILA/RESPA Integrated Disclosure Rule

The FDIC is providing guidance on its initial supervisory expectations in connection with its examinations of financial institutions for compliance with the Truth in Lending Act (TILA) – Real Estate Settlement Procedures Act (RESPA) Integrated Disclosure Rule (TRID Rule), which is effective October 3, 2015.

Read full letter.

Friday, October 2, 2015

This Week at the CFPB

A summary of this week's news about the CFPB from the ABIA and ABA Dodd-Frank Tracker:
The ABIA has a Task Force of members that work on issues related to the CFPB's regulation of insurance products. If you are an ABIA member and would like to learn more about ABIA's work with CFPB to educate them about the bank-insurance industry or join our CFPB Task Force, please contact us and visit our website.