July 16, 2014
Masthead 2

 
Contents:
Mortgage Lending Rules to Assist Surviving Family Members
Senate to View Cybersecurity Bill
Changes to Annual Privacy Notice Process
Guidance on "Mini-Correspondent" Brokers


Crowe-Horwath



A Bank's Private Cloud




6 Bridges




Harland Clarke


Travelers


 
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Mortgage Lending Rules to Assist Surviving Family Members 

The Consumer Financial Protection Bureau (CFPB)  issued an interpretive rule to clarify that when a borrower dies, the name of the borrower's heir generally may be added to the mortgage without triggering the Bureau's Ability-to-Repay rule.   

 

This interpretive rule explains that because an heir has already acquired the title to the home, adding the heir as a borrower on the mortgage does not trigger the Ability-to-Repay requirements. The rule does not require the creditor to determine the heir's ability to repay the mortgage before formally recognizing the heir as the borrower. As the named borrower, the heir may more easily be able to obtain account information, pay off the loan, or seek a loan modification. The interpretive rule can also apply to other transfers, including transfers to living trusts, transfers during life from parents to children, transfers resulting from divorce or legal separation, and other family-related transfers.

  

To view more of the clarification, click here.    

Senate to View Cybersecurity Bill 

The Senate Intelligence Committee approved a cybersecurity bill Thursday that aims to improve the country's cyber-defenses.

 

The Cybersecurity Information Sharing Act, a bill sponsored by Committee Chairman Dianne Feinstein (D-CA) and Saxby Chambliss (R-GA), would expand information shared about cybersecurity threats and defensive mechanisms between the government and companies within the private sector.  

 

The bill requires the director of national intelligence to increase the sharing of classified and unclassified cyber threat information to banks and other private sector companies, authorizes individuals and companies to monitor their own computer networks and those of their consenting customers for cyber threats, and puts in place liability protections for banks and other private sector companies that appropriately monitor their networks or share cyber information.

  

The Cybersecurity Information Sharing Act now heads to the Senate floor for consideration.   

 

View the Bill here.   

Changes to Annual Privacy Notice Process
ICBA, along with other trade
associations, sent a letter 
to the Consumer Financial Protection Bureau (CFPB) to raise concerns with the bureau's proposal to amend the provision under Regulation P that requires financial institutions provide an annual disclosure of their privacy policies to their customers.

The amendment would create an alternative delivery method for the annual disclosure, which financial institutions would be able to use under certain circumstances.

Among other requirements, the proposal would require annual reminders, a toll-free number for privacy policy requests and the use of model forms. While the reminder notice would be simplified, the process doesn't eliminate the annual distribution requirement. The letter also states that requiring a toll-free number would be an unnecessary hurdle - particularly for community banks that operate in small geographic footprints and do not need a toll-free line.

ICBA and the other trade associations recommend that the CFPB allow institutions to eliminate the annual privacy notice when institutions only share information within established restrictions and when have not changed their information-sharing practices since their last privacy notices were delivered. 
Guidance on "Mini-Correspondent" Brokers 
The Consumer Financial Protection Bureau issued guidance regarding mortgage brokers transitioning to a "mini-correspondent" lender model. The CFPB said it is concerned that some mortgage brokers might have the mistaken belief that identifying themselves as mini-correspondents would automatically exempt them from certain consumer-protection rules affecting broker compensation.

The guidance sets out how the bureau evaluates mortgage transactions involving mini-correspondent lenders. It also confirms which mortgage lenders must comply with the broker compensation rules, regardless of how they may describe their business structure.

View the CFPB Guidance in full here.  

Wednesday, July 23, 2014

Wednesday, July 30, 2014    

 

Mastering Business Development, Part 1: Results-Driven Foundational Skills  

August 13, 2014                                    No Cost Workshop!

Interagency CRA Training Workshop
This no-cost event will be held in partnership with the Federal Reserve Banks of Atlanta and St. Louis, Federal Deposit Insurance Corporation and the Barret School of Banking.