Banker's Compliance Consulting Blog

Banking Regulations Compliance | CFPB Mortgage Rules

Written by Diane Dean | Nov 13, 2014 9:01:06 AM

In case you missed it, CFPB updated their Mortgage Rules Readiness Guide back in September and it can be a good resource as we get closer to the August 2015 effective date for the Integrated Disclosures Rule.  It includes guidance regarding items you should keep in mind as you continue implementation efforts. The Guide and some additional tools to help you get ready can be found at the TILA-RESPA Integrated Disclosure Rule Implementation Page on the CFPB website.

If you have an exam coming up, you will probably be asked about your plan to prepare for these changes.  The Guide specifically notes that it may assist with examiner discussions. The Guide still contains references to other rules already in effect and although there is still value in reviewing those items, the discussion specific to the Integrated Disclosures begins on page 15.

Although the CFPB notes that the tools should not serve as substitutes for the Rule itself, there have been some inconsistencies noted between the actual regulation and some of the supplementary material. While the CFPB has tried to get these items updated, if you come across something that doesn’t match your prior understanding, it really is best to question it and try to find the answer in the Rule itself.