Reply by ReneeK_MI on 10/24/13 4:49pm
Msg #489664
Excellent question and going back a year in history ...
...might shed a little more light on today's 'frenzied' topics. Last I remember, they were taken to task (sued?) by one of the land title assoc - perhaps it was ALTA? The issue was the financial burden on the smaller agencies.
Interesting counter to that, re: the CFPB's issuing a "bulletin" rather than an actual regulation, relative to 3rd party SP risk:
http://www.klgates.com/unlucky-day-for-consumer-financial-servicer-providers--the-cfpb-issues-its-vendor-management-bulletin-on-friday-the-13th-05-11-2012/
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Reply by Susan Fischer on 10/24/13 7:28pm
Msg #489674
Excellent link. This bounced right out at me to bring it
home to NotaryWorld:
"Nor did the CFPB choose to attempt to determine what impact the Bulletin’s requirements might have on small businesses, which the CFPB is required to do under the Small Business Regulatory Enforcement Fairness Act (“SBREFA”) when implementing regulations. The SBREFA provides that if a proposed rule will have a significant economic impact on a substantial number of small entities, the CFPB must seek input directly from small entities about potential costs of a proposed rule and potentially less-burdensome alternatives before issuing the proposal for public comment. The CFPB has apparently attempted to avoid characterizing the third-party vendor requirements as a regulation by instead calling the document a “Bulletin” and calling the requirements mere “expectations.” However, the Bulletin has all the hallmarks of a regulation."
That's us. The teensy businesses. (It can't get smaller than one worker bee.)
With 'regs' like this coming down, without the public vetting we need to sort out the imperatives bulleted in the link, the messaging on our boards, following through by writing to principals in our Industry, are some tools we have to rattle chains and, as our fellow denizens just demonstrated, are not only being heard, but are participating in the process to make things better.
Great link.
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