The seismic shifts in the consumer financial services (CFS) regulatory landscape that began in 2017 continued throughout 2018. Additional changes are on the horizon as the new leadership of the Consumer Financial Protection Bureau (CFPB or Bureau) sets out to define future priorities.
As the Trump Administration, Congress and courts continue to rethink and reshape the structure and agenda of the CFPB, and as state regulators react to such changes, companies are dealing with the associated uncertainty regarding the CFS supervisory and enforcement landscape. To help institutions anticipate, adapt and respond to this rapidly evolving regulatory environment, we present a concise retrospective and guide to navigate the road ahead. Amidst the change witnessed over the past several years, and in an environment featuring strong deregulatory rhetoric, it remains paramount to take an intermediate and even long view toward compliance as the ramifications of decisions made today might not become apparent for years. As always, a commitment to best practices, a strong compliance culture and a firm grasp on enduring requirements will serve CFS market participants well.
Former Acting Director Mick Mulvaney oversaw a series of notable changes during his tenure at the Bureau, which ran from November 2017 until the confirmation of current Director Kathy Kraninger in December 2018. Former Acting Director Mulvaney initiated a sweeping review of the CFPB’s core processes and procedures, placed a moratorium on its (since resumed) enforcement activities and realigned its enforcement, supervisory and rulemaking priorities. The Bureau reorganized, for example by limiting the functions of the Office of Fair Lending and Equal Opportunity and the Office of Students and Young Consumers to outreach and educational responsibilities. These actions were met with strong opposition from consumer advocacy groups, Congressional Democrats and, in some cases, state regulators.
Although the CFPB adopted a less aggressive enforcement approach overall, the Bureau continued to employ similar legal theories and leverage its broad authority to prohibit unfair, deceptive or abusive acts or practices (UDAAP). The Bureau concurrently dialed down its fair lending enforcement activity to prioritize other areas reflecting higher consumer complaint volumes, such as disclosures and debt collection.
In light of the Bureau’s retrenchment, several state attorneys general (AGs) and regulatory agencies have used, or signaled their intent to use, their enforcement powers, including their ability under the Dodd-Frank Act to enforce violations of federal CFS laws, with many drawing on or otherwise forming special consumer units. Beyond enforcement, state AGs, regulators and legislators are further considering changes to existing laws, regulations and guidance—and enhancing multi-state coordination where feasible—all in the name of filling any perceived voids left by the CFPB.
While several legislative proposals were introduced in 2018 by Republicans to cut back the CFPB’s authority, none gained sufficient traction to pass the Republican-controlled House and Senate. Deep structural reforms are likely not on the horizon with Democrats now in control of the House. Rather, the House Financial Services Committee as chaired by Rep. Maxine Waters (D-CA) is expected to ramp up political pressure on Director Kraninger and scrutinize the Bureau’s strategies and priorities.
Former Acting Director Mulvaney left behind a full agenda, some of which has already been addressed by Director Kraninger. The Bureau recently finalized proposed revisions to its payday lending rule, and is expected to engage in rulemaking to modernize debt collection communications and to clarify the “abusive” prong under its UDAAP authority. The Bureau is also expected to revisit how it treats disparate impact claims under the Equal Credit Opportunity Act (ECOA).
Unlike former Acting Director Mulvaney, Director Kraninger will have the benefit of a full five-year term to develop her vision for the Bureau, albeit against the backdrop of increased congressional oversight and ongoing constitutional challenges to the CFPB’s leadership structure. Notably, comments received from the CFPB’s “Call for Evidence” will allow Director Kraninger to leverage industry insights to implement more substantial and organizational changes at the Bureau going forward.
CFPB structural changes
During his tenure, former CFPB Acting Director Mick Mulvaney brought significant changes to the Bureau’s structure and operations. As the new CFPB Director, Kathy Kraninger will have the benefit of a full five-year term to develop her vision for the Bureau’s strategy and priorities.
In 2018, the CFPB issued multiple rules, and Congress passed legislation, to clarify, revise and update the regulatory framework applicable to the home mortgage origination and servicing market.
In February 2019, the CFPB released the highly anticipated revamp of its Payday Rule, reinforcing its more lenient attitude towards payday lenders. In light of the Bureau’s softer touch, as well as similar developments at the banking agencies, we expect states to step into the void and take further action to curtail payday lending at the state level.
In 2018, the CFPB shifted away from student lending supervision and enforcement. We anticipate this trend to continue in the year to come, with states seeking to fill any voids left by the Bureau.
In 2018, the CFPB continued to pay attention to the auto finance industry, with a particular focus on indirect (dealer-arranged) auto lenders and unfair or abusive loan servicing practices.
The CFPB has traditionally not prioritized marketplace lenders in its supervisory and enforcement efforts. As a result, state regulators have increasingly sought to fill any perceived voids left by the Bureau.
Payment processing
The CFPB continued to be active in the consumer payments space in 2018, while the Federal Reserve and market participants considered the future of payment processing, including the development of faster payment systems.
In 2018, the CFPB issued multiple rules, and Congress passed legislation, to clarify, revise and update the regulatory framework applicable to the home mortgage origination and servicing market.
It is illegal for home lenders and banks to discriminate against applicants—and it sets city blocks and whole neighborhoods back. [W]e need to hear from consumers who believe they’ve been victimized in the home lending and banking industries so we can hold those responsible accountable.”
Pennsylvania Attorney General Josh Shapiro1
Section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA), which became law in May 2018, amended HMDA with the intent of decreasing the compliance burdens of smaller depository institutions. 3 The EGRRCPA also requires the Government Accountability Office (GAO) to submit a report to Congress by May 2021 evaluating the impact of the EGRRCPA’s changes on the amount of data available under HMDA.
In August 2018, the CFPB issued an interpretive and procedural rule to implement and clarify certain of the EGRRCPA’s changes to HMDA.4 Notably, the rule clarifies that insured depository institutions and insured credit unions covered by a partial exemption under the EGRRCPA have the option to report exempt data fields, provided they report all data fields within any exempt data point for which they report data.5 In addition, the rule clarifies that only loans and lines of credit that are otherwise HMDA-reportable count toward the thresholds for the partial exemptions.6 The Bureau also updated its Filing Instructions Guide7 and Small Entity Compliance Guide8 to reflect the EGRRCPA changes. In addition, in December 2018, the Bureau issued final policy guidance describing modifications it intends to apply to the HMDA data reported by financial institutions under HMDA and Regulation C before making such data available to the public at the loan level.9
The Bureau is currently considering amendments to Regulation C to address institutional and transactional coverage tests and discretionary data points, along with other changes to reduce the regulatory burden for mortgage-related activities.10 We expect the CFPB to issue a notice of proposed rulemaking, which would likely incorporate the August 2018 rule and further implement certain EGRRCPA provisions, by as early as spring 2019.11
We’re not [revising HMDA requirements] to undermine the consumer confidence in the system. We're actually doing it to help the marketplace. That’s what we are told to do in the statute.”
Former CFPB Acting Director Mick Mulvaney2
In March 2018, the CFPB also finalized an amendment to its 2016 mortgage servicing rule to clarify and, as of April 19, 2018, afford mortgage servicers more latitude in providing periodic statements to consumers entering or exiting bankruptcy.12
Section 101 of the EGRRCPA created a safe harbor under the qualified mortgage and ability to pay (ATR/QM) rule for certain mortgage loans originated by a depository institution or credit union with less than US$10 billion in total consolidated assets.13 The EGRRCPA also amended TILA to specify that mortgage appraisal services donated by a fee appraiser to an organization eligible to receive tax-deductible charitable contributions are deemed to be customary and reasonable and that a retailer of manufactured housing that meets certain requirements is generally not a “mortgage originator” subject to TILA requirements.14
In September 2018, the Office of the Comptroller of the Currency (OCC) issued an updated TILA booklet of its Comptroller’s Handbook.15 The booklet replaces a 2014 version and includes updated guidance and procedures to OCC examiners in connection with changes made to Regulation Z. In January 2019, the Bureau issued a five-year lookback report on the ATR/QM rule, as well as a five-year lookback report on its Real Estate Settlement Procedures Act (RESPA) servicing rule.16
In April 2018, the CFPB finalized an amendment to its TILA-RESPA integrated disclosure (TRID) rule to address the so-called “black hole” issue that prevented creditors from resetting tolerance (i.e., the percentage by which the amount ultimately paid by the customer is permitted to exceed the estimated amount), except in very limited circumstances.17 The April 2018 rule permits a creditor to reset these tolerances through closing disclosures regardless of the number of days between consummation and the required delivery date of the closing disclosure, provided that the creditor delivers the revised closing disclosure within three business days after receiving information sufficient to establish that a triggering event has occurred.18
In January 2019, the CFPB issued frequently asked questions and accompanying responses (FAQs) concerning the TRID rule. Three of the FAQs address the issuing of corrected closing disclosures and the three business-day waiting period before consummation, and the fourth states that lenders can rely on a safe harbor when using CFPB model disclosures, even if the model disclosures do not reflect recent rule changes.19 We also expect the CFPB to provide guidance pursuant to Section 109(b) of EGRRCPA on the applicability of the TRID rule to mortgage assumption transactions and construction-to-permanent home loans, and the conditions under which such loans can be properly originated.
2,957
mortgage-related complaints received each month by the CFPB since November 201642
The CFPB brought far fewer enforcement actions, including in the mortgage space, in 2018 than in 2017. After several months without initiating an enforcement action, the Bureau announced, in April 2018, a joint enforcement action with the OCC in which it reached a US$1 billion settlement with a major US financial institution for activities that included alleged mortgage servicing abuses, including improperly charging fees to borrowers for mortgage interest rate-lock extensions.20 As discussed below, multiple states and the District of Columbia reached a settlement with the same institution for related conduct.
In December 2018, the CFPB filed a complaint alleging that a loan company that offered a product to veterans with a loan guaranteed by the Department of Veterans Affairs to refinance their mortgages at lower interest rates, engaged in deceptive conduct by misleading customers by overstating the benefits of such refinancing.21 The settlement provides that the company will pay approximately US$270,000 in consumer redress and a civil penalty of US$260,000.22
Another notable enforcement action concerning alleged improper mortgage servicing practices remained pending throughout 2018. The Bureau filed a lawsuit against a leading nonbank mortgage servicer in 2017 for allegedly failing to provide routine servicing functions, including making widespread errors and runaround costs, failing to send accurate monthly statements, illegally foreclosing on struggling borrowers, ignoring customer complaints and selling off the servicing rights to loans without fully disclosing the mistakes it made in borrowers’ records. Litigation is ongoing in the United States District Court for the Southern District of Florida.23
The CFPB reported that from November 2016 through October 2018, mortgage products were the source of 11 percent of consumer complaints to the Bureau,24 down from 18 percent in 2016.25 Despite this reduction, we anticipate that the CFPB will continue to scrutinize the mortgage area, and in particular mortgage servicing practices. The most common source of consumer complaints was the payment process, including late or inaccurate periodic statements, servicers not applying payments to loan accounts as intended, escrow analyses showing a shortage of funds and payoff information requests that were not addressed or were inaccurate.26
The Bureau highlighted mortgage servicing as a top supervisory issue, and in particular, the loss mitigation process and how servicers handle trial modifications where consumers are paying as agreed.27 The Bureau noted that mortgage servicing examinations observed unfair acts or practices relating to conversion of trial modifications to permanent status and initiation of foreclosures after consumers accepted loss mitigation offers.28 In addition, examinations identified unfair acts or practices when institutions charged consumers amounts not authorized by modification agreements or mortgage notes.29
In 2017, the Department of Justice (DOJ) reached several settlements with banks and nonbank mortgage companies, as well as with a service provider to a nonbank mortgage company, under the False Claims Act (FCA) and the Fair Housing Act (FHA). As in recent years, the DOJ in 2018 frequently proceeded through joint actions with the Department of Housing and Urban Development. These enforcement efforts primarily focused on origination and servicing violations in connection with FHA-insured loans, as well as discriminatory lending practices. Such efforts notably included:
$200.7 billion
in mortgages originated since the CFPB creation43
Fintechs in the mortgage origination and servicing space have focused on developing software to assist mortgage lenders in complying with HMDA disclosure requirements and performing real-time audits of the entire mortgage origination process to reduce cost and risk exposure. Fintechs have also developed AI-based scoring algorithms used to evaluate alternative data sources and assess mortgage seekers’ creditworthiness, as well as provide more accurate mortgage origination pricing and rates.
In addition, many fintech and traditional mortgage lenders have digitized all or a portion of the mortgage origination process. In 2017, 43 percent of mortgage customers applied for a mortgage digitally, up from 28 percent in 2016.33 While many lenders now offer digital applications, fewer have digital capabilities through the full back end of the loan process.34 The transition to a fully digitized process, in which electronic mortgage notes replace paper notes, is currently challenged by the refusal of Ginnie Mae and the federal home loan banks to accept electronic notes.35
Research by the Federal Reserve Bank of New York suggests that the market share of fintech mortgage lenders increased from two percent to eight percent from 2010 to 2016. The research also indicates that fintech lenders process mortgage applications approximately ten days faster than traditional lenders, without increasing the credit risk of loans. As in other market segments, these tech-based solutions may raise novel and significant, fair lending considerations.
Against the backdrop of decreased CFPB enforcement actions and statements by former Acting Director Mulvaney, that states should take the lead in enforcing consumer protection laws, states continued to focus on mortgage origination and servicing in 2018.36
In December 2018, all 50 states and the District of Columbia reached a settlement with a major financial institution for, among other things, alleged mortgage servicing abuses that include improperly charging fees to borrowers for mortgage interest rate-lock extension.37
In another notable action, Maryland’s Consumer Protection Division and Commissioner of Financial Regulation entered into a settlement agreement in May 2018 with a large nonbank servicer of residential mortgages that allegedly charged homeowners illegal inspection fees. As a result of the investigation and settlement, the servicer returned to consumers approximately US$1 million in fees and paid a fine of approximately US$500,000.38 In April 2018, the New York Department of Financial Services (NYDFS) announced that it reached a settlement in excess of US$17 million with a large nonbank mortgage servicer for alleged violations of New York banking law, including document retention and document management processes that demonstrated significant flaws, as well as failure to fund mortgage loans within the required timeframe.39
Several states established or revised requirements that nonbank companies engaging in mortgage lending and/or mortgage servicing must obtain a state license, joining others that took similar action in 2017.40 In August 2018, the Conference of State Bank Supervisors (CSBS) announced that all US state and territories now use a single, common exam to assess mortgage loan originators (MLOs), simplifying the licensing process for MLOs. A mortgage license applicant that passes the national test will not be required to take any additional state-specific tests to hold a license with a US state or territory.41
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Consumer financial services: The road ahead
1 Press Release, Attorney General Shapiro Puts Spotlight on Redlining (Oct. 22, 2018), https://www.attorneygeneral.gov/taking-action/press-releases/attorney-general-shapiro-puts-spotlight-on-redlining/.
2 Kate Berry, CFPB's Mulvaney Plots HMDA Rollback, But it May Not Matter, American Banker (May 25, 2018), https://www.americanbanker.com/news/cfpbs-mulvaney-plots-hmda-rollback-but-it-may-not-matter.
3 Pub. L. 115-174 (Economic Growth, Regulatory Relief and Consumer Protection Act) (May 24, 2018), https://www.congress.gov/bill/115th-congress/senate-bill/2155/text#toc-id85fe90d9cb9347b5be06fbbf343b0cdf. EGRRCPA exempts from certain reporting requirements: (i) with respect to closed-end mortgage loans, insured depository institutions and insured credit unions that originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years, and (ii) with respect to open-end lines of credit, insured depository institutions and insured credit unions that originated fewer than 500 open-end lines of credit in each of the two preceding calendar years.
4 CFPB, Partial Exemptions from the Requirements of the Home Mortgage Disclosure Act under the Economic Growth, Regulatory Relief, and Consumer Protection Act (Regulation C) (Aug. 30, 2018), https://files.consumerfinance.gov/f/documents/bcfp_hmda_interpretive-procedural-rule_2018-08.pdf.
5 Id. at 2.
6 Id.
7 CFPB, Filing Instructions Guide for HMDA Data Collected in 2018 (Sept. 2018), https://s3.amazonaws.com/cfpb-hmda-public/prod/help/2018-hmda-fig-2018-hmda-rule.pdf.
8 CFPB, Home Mortgage Disclosure (Regulation C) Small Entity Compliance Guidance (Oct. 2018), https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/bcfp_hmda_small-entity-compliance-guide-final_2018-10.pdf.
9 CFPB, Disclosure of Loan-Level HMDA Data (Dec. 20, 2018), https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/HMDA_Disclosure_
FPG_--_Final_12.21.2018_for_website_with_date.pdf.
10 CFPB, Semiannual Regulatory Agenda: Home Mortgage Disclosure Act (Regulation C) (Fall 2018), https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201810&RIN=3170-AA76.
11 CFPB, Bureau of Consumer Financial Protection Issues Rule to Implement and Clarify New HMDA Amendments (Aug. 31, 2018), https://www.consumerfinance.gov/about-us/newsroom/bureau-consumer-financial-protection-issues-rule-implement-and-clarify-new-hmda-amendments/.
12 CFPB, Mortgage Servicing Rules under the Truth in Lending Act (Regulation Z) (Mar. 6, 2018), https://files.consumerfinance.gov/f/documents/cfpb_mortgage-servicing_final-rule_2018-amendments.pdf.
13 Pub. L. 115-174 (Economic Growth, Regulatory Relief, and Consumer Protection Act) (May 24, 2018), https://www.congress.gov/bill/115th-congress/senate-bill/2155/text#toc-id85fe90d9cb9347b5be06fbbf343b0cdf.
14 Id. at Section 102.
15 OCC, Controller's Handbook: Truth in Lending Act, Version 2.0 (Sept. 2018), https://www.occ.treas.gov/publications/publications-by-type/comptrollers-handbook/truth-in-lending-act/pub-ch-tila.pdf.
16 CFPB, Ability-to-Repay and Qualified Mortgage Rule Assessment Report (Jan. 2019), https://files.consumerfinance.gov/f/documents/cfpb_ability-to-repay-qualified-mortgage_assessment-report.pdf; CFPB, 2013 RESPA Servicing Rule Assessment Report (Jan. 2019), https://files.consumerfinance.gov/f/documents/cfpb_mortgage-servicing-rule-assessment_report.pdf.
17 CFPB, Federal Mortgage Disclosure Requirements under the Truth in Lending Act (Regulation Z) (Apr. 26, 2018), https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/cfpb_tila-respa_final-rule_amendments-to-federal-mortgage-disclosure-requirements.pdf.
18 Id. at 12-13.
19 CFPB, TILA-RESPA Integrated Disclosure FAQs (Jan. 25, 2019), https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/cfpb_TILA-RESPA-integrated-disclosure_frequently-asked-questions.pdf.
20 CFPB, Consent Order in the Matter of Wells Fargo Bank, N.A., 2018-BCFP-0001 (Apr. 20, 2018), https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/cfpb_wells-fargo-bank-na_consent-order_2018-04.pdf. This enforcement action is discussed further in White & Case's 2018 edition of Consumer Financial Services at a Crossroads, https://www.whitecase.com/publications/alert/consumer-financial-services-crossroads.
21 Consumer Fin. Prot. Bureau v. Vill. Capital & Inv, et al., case no. 2:18-cv-02304 (D. Nev. Dec. 4, 2018), https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/bcfp_village-capital_complaint_2018-12.pdf.
22 Consumer Fin. Prot. Bureau v. Vill. Capital & Inv, et al., case no. 2:18-cv-02304 (D. Nev. Dec. 4, 2018), https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/bcfp_village-capital_stipulated-final-judgment-order_2018-12.pdf.
23 Consumer Fin. Prot. Bureau v. Ocwen Fin. Corp., et al., case no. 9:17-cv-80495 (S.D. Fla. Apr. 20, 2017), https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/20170420_cfpb_Ocwen-Complaint.pdf.
24 CFPB, Complaint Snapshot: Mortgage, at 10 (Jan. 2019), https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/cfpb_complaint-snapshot-mortage_2019-01_liwsYNV.pdf.
25 CFPB, Complaint Snapshot: 50 State Report (Oct. 2018), https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/bcfp_50-state-report_complaint-snapshot_2018-10.pdf.
26 CFPB, Complaint Snapshot: Mortgage at 12, https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/cfpb_complaint-snapshot-mortage_2019-01_liwsYNV.pdf.
27 CFPB Supervisory Highlights, Issue 17 (Summer 2018), at 7-10, https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/bcfp_supervisory-highlights_issue-17_2018-09.pdf.
28 Id.
29 Id.
30 DOJ, Universal American Mortgage Company LLC (UAMC) Agrees to Pay $13.2 Million to Resolve False Claims Act Allegations Related to Loan Guarantees (Oct. 19, 2018), https://www.justice.gov/opa/pr/universal-american-mortgage-company-llc-uamc-agrees-pay-132-million-resolve-false-claims-act.
31 DOJ, Justice Department Reaches Settlement with Minnesota Bank to Resolve Allegations of Lending Discrimination (May 8, 2018), https://www.justice.gov/opa/pr/justice-department-reaches-settlement-minnesota-bank-resolve-allegations-lending.
32 DOJ, Deloitte & Touche Agrees to Pay $149.5 Million to Settle Claims Arising From Its Audits of Failed Mortgage Lender Taylor, Bean & Whitaker (Feb. 28, 2018), https://www.justice.gov/opa/pr/deloitte-touche-agrees-pay-1495-million-settle-claims-arising-its-audits-failed-mortgage.
33 J.D. Power, Despite a Rise in Use of Digital, Mortgage Customer Satisfaction Declines, J.D. Power Finds (Nov. 9, 2017), https://www.jdpower.com/business/press-releases/jd-power-2017-us-primary-mortgage-origination-satisfaction-study.
34 Treasury, A Financial System That Creates Economic Opportunities: Nonbank Financials, Fintech, and Innovation, at 102-103 (July 2018), https://home.treasury.gov/sites/default/files/2018-08/A-Financial-System-that-Creates-Economic-Opportunities---Nonbank-Financials-Fintech-and-Innovation.pdf.
35 Id.
36 John Vong, A Little Less Regulation from the CFPB, a Little More Action from the States, Housing Wire (Aug. 16, 2018), https://www.housingwire.com/blogs/1-rewired/post/46486-a-little-less-regulation-from-the-cfpb-a-little-more-action-from-the-states.
37 Settlement Agreement, by and among Wells Fargo Bank, N.A. and the Various Attorneys General (Dec. 28, 2018), https://portal.ct.gov/-/media/AG/Press_Releases/2018/20181228_WellsFargo_MultistateSettlement.pdf?la=en.
38 Attorney General of the State of Maryland, Press Release (May 14, 2018), http://www.marylandattorneygeneral.gov/Press/2018/051418.pdf.
39 NYDFS, Consent Order Pursuant to New York Banking Law § 44 (Apr. 11, 2018), dfs.ny.gov/about/ea/ea180411.pdf.
40 These states include California, Ohio, Oregon, Maine, Pennsylvania, and Washington. As of August 2018, 46 states required nonbank companies to have a specific license for mortgage servicing. See https://www.housingwire.com/blogs/1-rewired/post/46486-a-little-less-regulation-from-the-cfpb-a-little-more-action-from-the-states.
41 CSBS, State Regulators Nationwide Adopt Single Exam for Mortgage Licensing (Aug. 8, 2018), https://www.csbs.org/state-regulators-nationwide-adopt-single-exam-mortgage-licensing.
42 CFPB, Complaint Snapshot: Mortgage (January 2019), https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/cfpb_complaint-snapshot-mortage_2019-01_liwsYNV.pdf.
43 CFPB Consumer Credit Panel, Mortgage Origination Activity, https://www.consumerfinance.gov/data-research/consumer-credit-trends/mortgages.
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