Home Mortgage Disclosure Act: A sprint to the finish line
Managing HMDA compliance risk ahead of CFPB examinations.
The Consumer Financial Protection Bureau (CFPB) recently announced that it would start directly supervising “large and key” service providers. This represents an expansion of the CFPB’s supervisory oversight because until now the CFPB has only reviewed service provider compliance as part of its examinations of financial institutions. Although this expansion of supervision does not come with any additional requirements for financial institutions, they should still consider potential impacts and review their relationships with key service providers.
The CFPB has already started conducting baseline reviews of certain service providers, along with targeted assessments of those in the mortgage lending market. Despite the dynamic political environment, service providers should not take a “wait and see” approach regarding the ongoing CFPB court case or potential actions by the Trump Administration to change the CFPB’s leadership as Director Richard Cordray has publicly stated that the CFPB intends to continue conducting examinations and enforcing existing rules.
This Regulatory brief describes the CFPB’s expectations for service providers’ compliance management systems and financial institutions’ service provider risk management programs, with recommendations for both to manage compliance risks ahead of examinations.
A publication of PwC's financial services regulatory practice