- legal clarification of CFPB’s authority over insurance activities;
- preparation of a generic consumer “compliance” matrix;
- development of best practices for specific products and services;
- data collection on points and fees cap for Qualified Mortgages (QM) - see below for details;
- work with ABA President, Governor Keating, who meets regularly with CFPB Director Cordray to provide him a list of ABIA priorities pertaining to the CFPB.
The ABIA and ABA will be conducting a member survey to identify the institutions that are impacted by the QM Rule's 3% cap on points and fees, which includes charges for title and homeowners insurance retained by an affiliate of the lender.
Following his testimony at a House Financial Services Committee hearing, in which he was asked about the impact on affiliated institutions, CFPB Dir. Cordray expressed that he wants to see data from the bank-insurance industry on the impact of the points and fees cap. This is a positive step as it indicates CFPB's potential willingness for change if the data shows appreciable harm to affiliated companies and consumers.
In order to facilitate the data collection process, the ABIA and ABA will be sending a very brief survey to members in order to identify institutions impacted by the rule. Once this survey is completed, we will reach out to individual respondents who are have indicated they have gathered data on this issue and are able to share it with the ABIA and ABA.
If your institution or affiliate would like to participate in the survey, or if you know of an institution that should be included, please contact us.
**All data will be disassociated with the responding institutions.
What to learn more?
If you would like to join our CFPB Task Force or learn more about ABIA's work with CFPB to educate them about the bank-insurance industry, please contact us and visit our website.