View from CBA June 7, 2013

June 7, 2013

Want a Job?

From CFPB Posting:

"Chief of Staff position: We seek executives with experience in small to mid-sized organizations who understand the unique disquiet of moving rapidly towards a steady-state."

Unique disquiet? 

As a reminder, the CFPB's exam team is about 70% staffed up at the moment so there are opportunities there, as well. 

Coming Up:

We expect a proposal from the CFPB under its recent mortgage loan originator final rule to address an issue with credit insurance premiums. According to the CFPB, this will come out by end of June. See CBA's recent comment letter on the issue. 


Despite the new QM rules, the CFPB is confident banks will continue to offer non-QM loans at the same volume as today. Unfortunately, I am not as confident. Expect to see some type of CFPB guidance to encourage banks to stay in the arena. Our recent QM comment letter is available here and see our GR Update for more information. 

CFPB former Deputy Director Raj Date has started his own bank advisory firm. Read his take on regulatory scrutiny, obstacles to innovation and the underbanked. 

Deposit Advance Products (DAP)

Our Deposit Advance Working Group members met with representatives from the CFPB, OCC and FDIC this week to discuss recent developments regarding these products, specifically our concerns surrounding recent guidance from the OCC and FDIC. Please see below for more information about these meetings.  

Nothing like having four regulators overseeing and trying to make changes to banking products that have existed for 19 years. Another obstacle as we make our way through the regulatory olympics. 

Student Lending Update

In case you missed it, The Hill published CBA's Op Ed "The CFPB and the elephants in the classroom" this week. 

CBA's Board of Directors is Coming to Town

We are excited to welcome our Board of Directors to CBA Headquarters in Washington, DC next week. We have an ambitious schedule including several distinguished speakers and will discuss everything from small business lending and student loans to cybersecurity and many other CFPB issues.  

Banking on Youth 2013 Champs

My congratulations to CBA's Banking on Youth finalists for their outstanding entrepreneurial ventures, particularly our Grand Prize Winner TGIF-Turn Grease Into Fuel (John Perino of Rhode Island) and Audience Choice Award Recipient (Simone Bernstein of Missouri). Visit ourwebsite to read more about our finalists, sponsors and judges and to see pictures from the event. Thanks once more to all our bank sponsors (see below right) who made this program possible.