MReport March 2017

TheMReport — News and strategies for the evolving mortgage marketplace.

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46 | TH E M R EP O RT SERVICING THE LATEST O R I G I NAT I O N S E R V I C I N G DATA G O V E R N M E N T S E C O N DA R Y M A R K E T CFPB Works to Facilitate Implementation of Key Regulations The Bureau says it has provided guidance and worked to facilitate implementation and compliance of TRID, HMDA, and mortgage-servicing rules. T hree of the initiatives by the Consumer Finan- cial Protection Bureau (CFPB) that have had the biggest impact on the mort- gage industry—the TILA-RESPA Integrated Disclosure (TRID) rule (a.k.a. the Know Before You Owe, or KBYO rule), the updated Home Mortgage Disclosure Act (HMDA) rule, and the August 2016 up - dates to the mortgage servicing rules were highlighted in a report on the Bureau's activities from Q 4 2015 to Q 3 2016. In its fourth report to the House and Senate Committees on Appropriations covering October 1, 2015, through September 30, 2016, the Bureau laid out some of the materials and help it provided during that 12-month period to assist institutions implementing those three initiatives. "As the Bureau has issued regulations to implement Dodd- Frank Act requirements, it has focused intently on supporting the implementation process for these rules with both industry and consumers," the CFPB stated in the report. "The Bureau has provided substantial implementa - tion support for these regulations, including engaging in public outreach, speaking at conferences, and publishing guides, summa - ries, charts, webinars, and other resources." The implementation of TRID, which went into effect on October 3, 2015, caused no small amount of consternation among mortgage lenders and other stakeholders in the industry. Among the help the CFPB provided are several imple - mentation resources that include a plain-language guide containing an overview of TRID's key aspects and illustrated instructions on how to complete the new Loan Estimate and Closing Disclosure Forms. The Bureau has also con - ducted several public webinars on TRID to answer specific questions on the implementation and/or interpretation of the rule's require - ments the Bureau has received since the rule went into effect. In July 2016, the Bureau pro- posed updates to TRID aimed at providing greater clarity and certainty surrounding the rule. "The proposed changes would augment implementation of the KBYO rule, which took effect in October 2015, and further help to facilitate compliance within the mortgage industry," the CFPB stated. "Bureau staff continues to engage in outreach and market monitoring activities to identify implementation issues as they arise, and provide informal oral guidance in response to interpre - tive inquiries from a myriad of stakeholders." The CFPB issued its updated HMDA rule in October 2015 along with resources to help industry stakeholders understand and implement the new rule, including a summary and overview of the final rule; a timeline of the rule's effective dates; coverage charts for financial institutions to determine if they are HMDA reporters; a summary of reportable data explaining the HMDA data points that are to be collected, recorded, and reported per the updated rule; a compliance guide with a plain- language explanation of the rule; a webinar with an overview of the final HMDA rule; and a number of data submission resources for HMDA filers available on the CFPB's website. "In addition to publishing im - plementation resources, the Bureau continues to engage in extensive outreach activities, including speaking at conferences and other events to support the implemen- tation of new HMDA mortgage lending data reporting rules and to identify and address implementa- tion issues," the Bureau said. The CFPB published a number of resources along with the August 2016 updates to its mort- gage servicing rules, including a summary of the new rule, a fact sheet, and a table summarizing how the rule affects small ser- vicers, and a fact sheet explaining the definition of "delinquency" under the new rule and how the new rule applies to TILA-RESPA requirements. "The Bureau plans provide additional support to facilitate implementation and compliance with the August 2016 amend- ments to the mortgage servicing rules, and to update the existing compliance guide to reflect the August 2016 amendments," the CFPB reported.

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