View from CBA - June 5, 2015

Update on TRID
On Wednesday, CFPB Director Richard Cordray announced the Bureau’s enforcement will be sensitive to those mortgage lenders seeking to comply in good faith with the CFPB’s TILA-RESPA Integrated Disclosure (TRID) regulation. As the industry approaches the date for transition to the new mortgage disclosure rule taking effect August 1, 2015, we welcome the Director’s decision finally to recognize good faith compliance efforts, but we believe even greater protection from liability is warranted. As we have said, this is a colossal undertaking dependent on timely deliverables from outside vendors which requires significant testing and training. Our members have worked diligently to meet the deadline in order to not delay consumers’ access to credit. Ultimately, we all share the Bureau’s goal of achieving a more streamlined consumer experience in mortgage origination. (Please see below for more detailed information.)
CFPB’s Information Gathering Burdensome to Vendors
Dodd-Frank gives the CFPB the authority to gather information in order to better inform the Bureau’s activities. This week, news reports highlighted its most recent attempts to compile information and the impact on the businesses who have to provide it. Presumably to inform its future overdraft rulemaking, the CFPB has requested anonymized information about overdraft services from vendors. Those receiving requests for information are Fiserv, FIS Global, and Jack Henry. There seems to be a disconnect in the Bureau’s idea of the resources required to comply with this request. We encourage the Bureau to be mindful of the fact that the cost of staff time and resources is often transferred to the consumer. Perhaps the CFPB should consider compensating companies for their time.
The Times They Are a-Changin’
Last year, the L.A. Times reported 128 million Americans no longer have landline phones. Roughly 19 percent of Americans are living without cable and instead choose to use internet streaming services—this includes some CBA team members. CBA member banks are often the first to recognize change, so it came as no surprise when I read the WSJ story about JPMorgan Chase doing away with some of its voicemail services. In a continued effort to trim expenses and grow profitability, Gordon Smith, chief executive of J.P. Morgan’s consumer and community bank, noted “…hardly anyone uses voicemail anymore…we’re all carrying something in our pockets that’s going to get texts or e-mail or a phone call to you.” So, it has been more than 50 years since Bob Dylan released his hit The Times They Are a-Changin’, but the message may be more apt today than it was in 1964.
Team CBA Visits the Buckeye State
Liz Terry and I met with Fifth Third and Huntington bankers in Columbus yesterday for some lively discussion. Fifth Third’s Mark Erhardt, SVP, Retail Product Management, Tom Ruebel, SVP, Director of Government Affairs, and Danielle English, VP, Government Affairs, shared their thoughts on the latest TRID updates and the legislative agenda on the Hill. Huntington’s Stephen Steinour, Chairman, President and CEO, CBA Board Member Mary Navarro, Senior Executive Vice President, Retail and Business Banking Director, and Barbara Benham, Executive Vice President, Chief Communications Officer, pulled together their team to discuss today’s state of retail banking and the regulatory impact to the industry. Many thanks to all of our bankers for sharing their time and opinions with us!

CBA Executive Banking School’s Faculty Spring Training
With the next session of the Executive Banking School just six weeks away, preparations are in full swing. Last weekend, 24 CBA Executive Banking School core faculty members met at Furman for "spring training,” the final walk-through of all the courses and logistics for the resident session in July. 

What We’re Reading
Shadow banks grab record US loans share – FT
President Warren Declares – WSJ
Real reason behind CFPB’s new payday regs – The Hill
Banks’ Billions in Overdraft Fees Seen Dodging Tough Regulations – Bloomberg
Thanks again for spending some time at CBA headquarters Paul Wible, Senior Executive Vice President at Bank of the West. Great to see you!
Michael Tipsord, State Farm president and chief operating officer, has been tapped to succeed outgoing Chairman and CEO, Edward B. Rust Jr, in September.
Congratulations to Sarah Long, a former member of the CBA Government Relations Council, on being named the new president of the Delaware Bankers Association.