If change was our mantra for the last 18 months, then change AND flexibility will have to be our mantra for the coming year while we all work on the best way to implement the new mortgage rules. The CFPB recently proposed modifications to several of the mortgage rules that were issued in January. The CFPB plans to continue to evaluate their rules as financial institutions implement the changes, to determine whether additional revisions or clarifications are needed. That means as you continue to develop your implementation plan you need to be prepared to adjust your strategy to ensure it meets the demands of any new clarifications or revisions issued throughout the rest of the year.
Unlike the final remittance transfer rule that was delayed when additional changes were made, the January implementation dates will likely still be in effect, even if the proposed changes are approved. In fact the CFPB is now proposing that certain provisions of the Loan Originator Compensation rule become effective on January 1 (nine days earlier than the final rule originally stated).
Information concerning the recent proposed changes to the final rule can be found here. The proposed changes include:
- An outline of procedures for obtaining follow-up information on loss-mitigation applications;
- Facilitating servicers’ offering of short-term forbearance plans;
- Facilitating lending in rural or underserved areas;
- Clarification about financing of credit insurance premiums;
- Clarifying the definition of a loan originator;
- Clarifying the points and fees threshold for manufactured housing employees; and
- Revising effective dates of the Loan Originator rule and ban on financing of credit insurance.
As your team develops its strategy for implementation, make sure it is flexible and can accommodate continued adjustments to the new mortgage rules because this is not the last of the changes we will see from the CFPB.