Dodd Frank Update

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Blair Rug discusses Dodd Frank Updates as they relate to community financial institutions.

Published in: Economy & Finance
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Dodd Frank Update

  1. 1. Join The Inner Circle! DODD FRANK AND THE CONSUMER FINANCIAL PROTECTION BUREAU Chicagoland Compliance Conference Presenter: by Blair Rugh© 2012 TriNovus, LLC.
  2. 2. Consumer Financial Protection Bureau• It answers to no one.• Exclusive and unlimited rule making authority.• Principal Objective - To protect consumers from unfair, deceptive and abusive acts and practices by financial institutions. TriComply from TriNovus: www.trinovus.com
  3. 3. CFPB Announced Goals• Delete unnecessary regulations• Create consumer understandable disclosures• Understand issues of community banks TriComply from TriNovus: www.trinovus.com
  4. 4. The CFPB: What We Know By Now• When complete, will have a staff of 2000 and an annual budget of $600,000,000.• It doesnt understand banking.• It is verbose.• It’s consumer bias is overwhelming.• The CFPB is not your friend. TriComply from TriNovus: www.trinovus.com
  5. 5. CFPB Significant Divisions• Office of Women and Minority Inclusion• Office of Fair Lending• Office of Service Members Affairs• Office of Financial Protection for Older Americans TriComply from TriNovus: www.trinovus.com
  6. 6. Regulations To Come• Combined RESPA and Reg. Z disclosures• RESPA and Regulation Z mortgage servicing rules o Forced placed flood insurance o Requests for information and information management o Early intervention – loan mitigation• Zero/zero alternate loan• MLO Compensation• Expanded HMDA reporting - up to eleven new data elements• HMDA like reporting for CRA• Ability to pay• New appraisal rules TriComply from TriNovus: www.trinovus.com
  7. 7. My Biggest Concerns• Fair Lending o Whole division dedicated to it o Office of Women and Minority Inclusion o New HMDA and CRA reporting rules• Ability to pay• UDAAP - What was fine yesterday may be illegal today• CFPB effect on other agencies TriComply from TriNovus: www.trinovus.com
  8. 8. Suggestions• Get a good pair of reading glasses• Dont overreact to proposed regulations• Get your fair lending house in order• Dont lose your sense of humor TriComply from TriNovus: www.trinovus.com
  9. 9. THANK YOU! 9

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