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They did publish their Fall 2018 agenda, which has been abridged and is summarized below.


Fair Debt Collection Practices Act – Notice of Proposed Rulemaking March 2019.


Although many institutions reading this article are not directly subject to the rule, the CFPB receives many complaints regarding debt collection. The initial com- ment period ended in 2014, and their agenda promises a Notice of Proposed Rulemaking in the spring of 2019. Regardless of what they do, this should not have any signi cant impact on banks.


Higher Priced Mortgage Loan Escrow – Pre-Rule Activity June 2019


The Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA) requires the CFPB to change the rule to exempt banks under $10 billion from this HPML rule. This seems simple enough, but they have delayed any action until June 2019, and they are calling that “Pre-Rule Activity.” Since this is now a law and should be fairly simple, there does not appear to be any reason for this delay.


Home Mortgage Disclosure Act – Notice of Proposed Rulemaking March 2019


The CFPB has issued information that essentially puts a band aid on the current regulation and has given some major relief to smaller mortgage lenders, but they have not updated the regulation to comply with the EGRRCPA. This has made 2018 data collection “messy,” and since they do not intend to even start changing the regulation until a Notice of Proposed Rulemaking until March 2019, it seems likely that data collection will probably remain problematic through at least 2019.


Expedited Funds Availability Act – Notice of Proposed Rulemaking October 2018


The original Notice of Proposed Rulemaking was delivered by the Federal Reserve Board in 2011. Now, seven years later, the CFPB is threatening (not for


the  rst time) to publish another Notice of Proposed Rulemaking very shortly. The changes will most likely be signi cant, as the current rule was written during the era where all checks went through the system as paper items. At least,  nally, this process may be moving forward.


Fair Credit Reporting Act In response to the EGRRCPA discussed above, the CFPB did order the national credit bureaus to start offering all consumers the right to “lock” their credit reports. In the short term, there will probably not be a big rush to do so, but over time, this could be one of your bigger problems. If a consumer has locked their credit report with all three major companies, and you need a tri-merge credit report, there will be many more steps to allow that to occur. Even for a simple unsecured loan, you could have a situation where you cannot get the credit report due to a “lock,” the consumer cannot remember their unlock password, and the result is a multi-day ordeal.


This is where we are right now, and we will all have to continue to pay very close attention to the regula- tions that are being promulgated. We encourage all banks to respond with comments whenever a regulation comes out to assure that both the consumer and the bank are well protected.


Are you concerned about staying up-to-date on all the regulatory and compliance changes? Join CBA’s Community Bankers for Compliance (CBC) program today. As part of the CBC program, you’ll receive access to resources to help you streamline regulatory tasks with utmost accuracy — while saving on compli- ance costs at the same time.


In fact, the CBC Program is the most successful and longest running compliance training program in the country. It has approval from the regulatory agencies for its comprehensiveness and practicality. One of the tools you’ll have access to as a CBC member is the Compliance Hotline for Quick Response. Members of the program may call a toll- free number or go online for compliance questions that arise on a daily basis. This service ensures that your bank is just a phone call away from the infor- mation you need. Contact the CBA of ce for more information about joining CBA’s CBC Program. 


NOVEMBER-DECEMBER 2018 WWW.CBAK.COM 17


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