In January of 2013, the Consumer Finance Protection Bureau (CFPB) becomes “THE” mortgage regulator for all institutions. Regardless of who wins the elections, it will be very improbable that it will change. It will take a super majority in the Senate (60 votes) to cut off a filibuster to change or abolish the CFPB. The CFPB can make changes that affect Real Estate Mortgage Loan Officers (RMLO) immediately and without prior notice.
As we have seen with the Anti-Money Laundering (AML) Policy, there may be other regulations that have gone unnoticed until its effective date jumps up to bite us. The term “Change Management” has become popular recently, which means any RMLO should establish a department to follow and update the company’s compliance with the new guideline. Most RMLO do not have the staff or capability to set up such a department. It appears the lenders will have to search for another vendor to support compliance requirements. There are few vendors who are staff properly to manage clients “Change Management” for updating QC plans and policies and with the knowledge to investigate and process suspicion in AML. The best fit is vendor who understands bank compliance, fraud investigations, and how to find misrepresentation in assets, income, and gifting in mortgages.
Chip Langley, CRMS is an anti-money laundering and compliance integration specialist at Quality Mortgage Services LLC. He may be reached by e-mail at [email protected]