Posted by Linda_in_IN on 12/13/13 9:31am
Msg #496005

CFPB - "No excuse for non compliance"

This article just came into my mailbox as part of an email with headlines from the past 24 hours. Sometimes nothing, but in this case there may be a lot of reading for me. The first link contains the release about non-compliance, changes to different documents, and explanations on those changes. I'm still drilling down within the one of the first links to see exactly what is what. So far in a very quick search, the only mention remotely related to notaries is within the Readiness Guide and is titled Third Party and Vendor Relationships. That section still doesn't have a lot of specifics as they are apparently leaving that up to the individual entities. There is reference to downloadable reference guides as well as videos explaining some of the overall changes.

"The updated, 21-page guide includes changes made to Regulation Z, which is the implementing regulation for the Truth in Lending Act (TILA), and to Regulation X, the implementing rule for the Real Estate Settlement Procedures Act (RESPA)."

http://reversemortgagedaily.com/2013/12/12/cfpb-to-lenders-no-excuse-for-non-compliance-with-new-rules/

The link below to the guidance page also contains a listing of the various publications that have come out of CFPB to date.

http://www.consumerfinance.gov/guidance/

Reply by C. Rivera Chicago Notary Services on 12/13/13 10:16am
Msg #496010

Thanks for the information Linda! n/m

Reply by Notarysigner on 12/13/13 10:23am
Msg #496013

Thinks for the info

Reply by JanetK_CA on 12/13/13 2:06pm
Msg #496047

Haven't read through all this yet, but just wanted to comment that I don't expect to see specific reference to notaries in any of these materials. We likely fall under the category of sub-contractors to the lenders' service providers (e.g. title companies), which should include signing services, too. So I don't think anyone should think that we're not covered by this, just because we're not mentioned directly.

Thanks for providing all this, although it looks like there's enough reading here to keep someone busy for a month!

Reply by Bear900/CA on 12/15/13 2:46am
Msg #496162

This is all about QM and ATR as mentioned in the article

Please see message Msg #495932 for a reader's digest and how it will impact us.

These emails have been blasted all day long everyday from every source (I.E. Reverse Mortgage Daily) and will probably continue well into January.

The rules were announced January 10, and the last official update was Oct 15 so the mad scramble is on now for lenders and originators to fully understand the the 3% fee cap and to make sure they are compliant with QM for safe harbor. I don't know of any originators too concerned since credit standards have been tightened long ago. There are some mechanics that need to be put in place though.

We're not running around with our hair on fire. BUT, add these new rules to the general slowdown predicted for 2014 and we have some signing slow-down issues.

There are a number of webinars happening daily that you might find by Googling and that will spare you from reading the rules. I would be happy to answer any questions if I can.

Best!

State Delegate
CA Association of Mortgage Professionals