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compliance monthly

May 2015
Compliance Monthly is intended to keep you informed of regulatory changes in advance of their effective
date so your institution can have the necessary policies, procedures and processes in place to be compliant
at the time of enactment.
Finalized Rules:

Other Compliance News:

Final Rule to Suspend Submission of


Credit Card Agreements

CFPB Replaces Settlement Cost Booklet


with the Home Loan Toolkit

The CFPB approved a final rule that temporarily


suspends a requirement that each quarter certain
credit card issuers send their agreements to the
CFPB, which publishes them in a public database on
its website. The submissions are to be suspended to
make it easier for the CFPB to improve the database
and streamline the data submission process. The
temporary suspension applies to the next four
quarterly submissions that were due April 30, July 31,
Oct. 31 and Jan. 31. The rule does not suspend the
requirement for issuers to post agreements publicly
on their own websites.

CFPB Updates Interpretive Rule on


Homeowner Counseling Lists

The CFPB issued a final interpretive rule restating


and expanding upon its November 2013 guidance
on how to provide mortgage applicants with a list
of local homeownership counseling organizations.
The rule includes instructions about: how to provide
applicants abroad with homeownership counseling
lists; permissible geolocation tools; combining the
homeownership counseling list with other disclosures;
use of a consumers mailing address to provide the
list; and high-cost mortgage counseling qualifications
and lender participation in such counseling. The
updated rule will become effective upon publication
in the Federal Register.
Proposed Rules:
None.

The CFPB has announced its release of a new


toolkit to guide consumers as they shop for a home.
Creditors must provide the Toolkit, referred to in the
TILA-RESPA Integrated Disclosure rule as the special
information booklet, to mortgage applicants as
a part of the application process. The Toolkit is
designed to be used in connection with the new
Loan Estimate and Closing Disclosure forms that will
be effective on August 1. The toolkit will replace the
current HUD-designed Shopping for Your Home Loan,
Settlement Cost Booklet, which should continue
to be used in connection with any mortgage loan
applications received before August 1.
The toolkit provides a step-by-step guide to help
consumers understand the nature and costs of real
estate settlement services, define what affordable
means to them and find their best mortgage. The
toolkit features interactive worksheets and checklists,
conversation starters for discussions between
consumers and lenders and research tips to help
consumers seek out and find important information.

CFPB Issues Exam Procedures for TILA/


RESPA Disclosures to Review Credit Card
Market
The CFPB released updated examination procedures
to help financial institutions know what to expect
from exams after the TILA/RESPA integrated
mortgage disclosures take effect August 1.

accumepartners.com

Compliance Monthly
May 2015

FFIEC Issues Joint Statements on Cyber


Attacks Compromising Credentials and
Malware

The Federal Financial Institutions Examination


Council (FFIEC) issued a statement to notify financial
institutions of the growing trend of cyber attacks for
the purpose of obtaining online credentials for theft,
fraud or business disruption. These attacks include
theft of users credential, such as passwords, user
names and e-mail addresses and other forms of
identification that customers, employees and third
parties use to authenticate themselves to systems.
Financial institutions should address this threat by
reviewing their risk management and controls over
information technology networks and authentication,
authorization, fraud detection and response
management systems and processes.
The FFIEC also addressed the increasing threat of
cyber attacks involving destructive malware and
recommended risk mitigation techniques. An
institutions management is expected to maintain
sufficient business continuity planning processes
to ensure the rapid recovery, resumption and
maintenance of the institutions operations after a
cyber attack involving destructive malware.

revised Private Mortgage Insurance


Eligibility Requirements

The Federal Housing Finance Agency (FHFA) has


announced that Fannie Mae and Freddie Mac are
issuing revised requirements for private mortgage
insurance companies that insure mortgage loans
either owned or guaranteed by the two government
sponsored entities. The revised eligibility requirements
set financial and operational standards that private
mortgage insurers must meet to receive approved
insurer status with Fannie or Freddie and are designed
to reduce their risk. The requirements are effective
December 31, 2015.
Copyright 2015 Accume Partners, All rights reserved.
Information contained in Compliance Monthly is not intended to
provide specific advice and guidance. You should consult your own
professional services provider in connection with matters affecting
your own interests.

OCC Updates RESPA Handbook

The OCC has issued Bulletin 2015-25 announcing the


issuance of a revision of the Real Estate Settlement
Procedures Act booklet of the Comptrollers
Handbook. The new booklet covers the transfer of
rulemaking authority for Reg X to the CFPB, as well
as new mortgage servicing requirements, new loss
mitigation procedures, new prohibitions related to
borrower assertions of error and new servicing-related
exam procedures.

accumepartners.com

accumepartners.com

Compliance Monthly
May 2015

about accume partners


Accume Partners provides the financial industry with regulatory compliance, internal audit, technology
and enterprise risk management services. Through these key areas of focus, Accume is able to remain at
the forefront of changing needs and regulations of its clients, bring balanced perspectives and the specialized
knowledge necessary to serve todays banks and financial institutions.

To learn more, please visit our website at accumepartners.com.


For more information, please call or e-mail any of these Accume Partners contacts:
Steven Peck
Managing Director, Compliance
610.803.1617
speck@accumepartners.com

David Smith
Director, Compliance
570.606.7423
dlsmith@accumepartners.com

James Nemecek
Director, Compliance
215.565.6576
jnemecek@accumepartners.com

Mark Lindig
Chief Executive Officer
646.476.1961
mlindig@accumepartners.com

Paul Nobbs
Managing Director, NJ Banking
and
Financial Services
609.332.7132
pnobbs@accumepartners.com

Nicole Lloyd
Managing Director, Mid-Atlantic
717.903.3142
nlloyd@accumepartners.com

Glenn Hoffman
Managing Director, Technology
Risk
Management
203.803.7345
ghoffman@accumepartners.com

K.D. Mehra
Managing Director, NY Banking
347.576.5652
kmehra@accumepartners.com

1.888.696.1515 accumepartners.com
Copyright 2015 Accume Partners, All rights reserved.