In case you missed it, CFPB updated their Mortgage Rules Readiness Guide back in September and it can be a good resource as we get closer to the August 2015 effective date for the Integrated Disclosures Rule. It includes guidance regarding items you should keep in mind as you continue implementation efforts. The Guide and some additional tools to help you get ready can be found at the TILA-RESPA Integrated Disclosure Rule Implementation Page on the CFPB website.
If you have an exam coming up, you will probably be asked about your plan to prepare for these changes. The Guide specifically notes that it may assist with examiner discussions. The Guide still contains references to other rules already in effect and although there is still value in reviewing those items, the discussion specific to the Integrated Disclosures begins on page 15.
Although the CFPB notes that the tools should not serve as substitutes for the Rule itself, there have been some inconsistencies noted between the actual regulation and some of the supplementary material. While the CFPB has tried to get these items updated, if you come across something that doesn’t match your prior understanding, it really is best to question it and try to find the answer in the Rule itself.
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!