CFPB Report November 27, 2013

November 27, 2013

CFPB Releases Compliance Study Results

In a blog post on Friday, November 22, 2013, the CFPB released the results of its case studies on regulatory compliance operations. The Bureau reviewed compliance costs at seven banks, ranging in size from less than $1 billion to more than $100 billion in assets, to determine direct impact of the rules on banks, to identify burdens, and how costs affect pricing, product availability, and competition. The rules studied were those in the area of deposit accounts, checking accounts, overdraft protection, debit cards, and related issues.   

The CFPB also evaluated compliance activities, focusing on incremental costs necessary to comply, as well as to demonstrate compliance, including labor, information technology and training costs. The studies did not, however, focus on opportunity or litigation costs, or the benefits of the rules. Among its findings, the Bureau acknowledged the size of the bank was a factor. 

The CFPB emphasized no broad conclusions could be drawn from the research, but offered the results to those interested in building on its research. The CFPB is also soliciting feedback from the industry on the studies.

CBA Submits Comment on Servicing Interim Final Rule

On Friday, November 22, 2013, CBA submitted a joint-trade comment letter regarding the CFPB’s interim final rule amending certain provisions related to mortgage servicing under the Truth in Lending Act and the Real Estate Settlement Procedures Act.

While CBA stated its support for the interim final rule, the Association highlighted these as the third set of amendments to the Servicing Rules in nine months. “While these revisions have been helpful, keeping up with the evolving rules has been a significant challenge for many of our members. We are concerned that additional compliance questions and operational hurdles remain and that servicers will identify new issues as they begin to more fully understand regulatory expectations and customize and implement vendor software,” CBA stated in its letter to the Bureau. “In sum, the implementation period has been too short for a brand-new regulatory structure of this size and complexity. A limited extension of the implementation period would best assure an orderly transition to the new servicing requirements."

CBA also addressed concerns as to the ability of servicers to provide periodic statements to borrowers whose loans have been charged off, asking the CFPB “not require servicers to provide periodic statements that meet all of the content and layout specifications for periodic statements.” 

CFPB Issues RFP on Consumer Education and Engagement Efforts

On Friday, November 22, 2013, the CFPB issued a request for proposals to acquire contractor support for the Division of Consumer Education and Engagement’s Integrating Financial Coaching into Service Delivery for Transitioning Veterans and Economically Vulnerable Consumers project. The proposal outlines the need for contractual support for the Office of Research, Markets & Regulations Card Market Team within the CFPB, in the collection, transmission, validation, aggregation, reporting, storage, and analysis of credit card data. Proposals will be accepted until January 6, 2014.