listen

November 21, 2017

Rod Alba from the ABA joins me again and talks about what we should expect in the days and months going forward with new acting CFPB director Mick Mulvaney. Mick is a staunch conservative with disdain for the Bureau, questioning not only the Constitutional nature of its structure but also it's "absurd rules". How will he change it? What's ahead in the next 12-18 months?

 

November 17, 2017

Washington, DC-based Rod Alba (senior counsel with the American Bankers Association) joins me to discuss next steps for the Consumer Financial Protection Bureau in the wake of yesterday's resignation of Director Richard Cordray. Will this important change signal the end of the Bureau's current agenda and usher in a new era of relaxed enforcement? Find out what we should expect.

 

November 14, 2017

Listen in as we continue our discussion with Jerra about the cross-qualification problem. In our last podcast, we learned about the cross-qual conundrum. Now, you'll learn how to educate your LOs about the right way to handle them.

 

November 7, 2017

Cross-Qualification = when the listing agent demands that your loan officer send a borrower's personal financial information, credit report and/or AUS findings to a competing lender prior to submitting an offer...or something like that.

Just so you know, the practice may violate GLBA and the lender's own privacy policy. It may violate the lender's contracts with the GSEs. It is also very likely that an underwriting decision is taking place, invoking disclosure requirements that aren't being complied with under TRID, TILA, RESPA, required reporting that isn't taking place under HMDA and treatment/disclosures not happening under ECOA if the loan is not approved. And we haven't even touch...

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roger@fendelmanconsulting.com

636.399.0169

 

The information contained herein is opinion only and is not, nor should it be construed as, legal advice. No attorney-client relationship exists. This is not attorney advertising and is not a solicitation for legal services.

© 2017 Roger Fendelman. All rights reserved. "Bridging the Gap Between Compliance and Technology" and "Compliance Insiders" are service marks of Roger Fendelman.