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The Legislative and Regulatory Landscape

The Legislative and Regulatory Landscape. - - presented by – Jack Konyk Executive Director, Government Affairs Weiner, Brodsky, Sidman, Kider PC - - for - -. The Regulatory and Legislative Landscape. What has happened or is happening now? How is the landscape changing ?

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The Legislative and Regulatory Landscape

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  1. TheLegislative and RegulatoryLandscape - - presented by – Jack Konyk Executive Director, Government Affairs Weiner, Brodsky, Sidman, Kider PC - - for - -

  2. TheRegulatory and Legislative Landscape • What has happened or is happening now? • How is the landscape changing ? • What will the new landscape hold ?

  3. TheRegulatory and Legislative Landscape • What has already happened or is happening now? • LOTS of controversy with LOTS of existing regulations • TILA – L O Compensation and Appraisal Independence • RESPA – still trying to clarify GFE/HUD-1 questions • SEC – regulations overturned on procedural technicality • New bureaucracies created • CFPB fully operational (but controversially) • Existing regulators coping with new responsibility alignment • And there’s another election coming up!

  4. TheRegulatory and Legislative Landscape • How is the landscape changing ? • Bureau of Consumer Financial Protection (CFPB) up and running • Became real on July 21, 2011 • Major functional areas have been busy • Cordray given recess appointment as Director; Republicans furious!

  5. TheRegulatory and Legislative Landscape • How is the landscape changing ? • Bureau of Consumer Financial Protection (CFPB) up and running • Became real on July 21, 2011 • Major functional areas have been busy • Cordray given recess appointment as Director; Republicans furious! • Other existing regulators coping with transition of authorities • Existing reg’s re-published without changes; new rules in development (QM, QRM, etc) • Some affected staff transferred, but often NOT to similar positions • Still other things require JOINT working with CFPB, so coordination needs managed • Lots of posturing for the 2012 election impacting operations • House has passed many bills that would change the Bureau • Bureau anxious to put so much in place that modifications will be difficult to achieve • Political backlash from recess appointment needs to play out

  6. TheRegulatory and Legislative Landscape • How is the landscape changing ? • Bureau of Consumer Financial Protection (CFPB) will need data to: • Collect, research, monitor, and publish information about the functioning of consumer financial products, services and markets to identify risks • Collect, investigate and respond to consumer complaints • Supervise and examine their institutions for compliance • Other existing regulators will ALSO need data to: • Supervise and examine their institutions for compliance (Multi-State or individual) • Facilitate the new Multi-State Mortgage Committee “e-Exam” • Collect, investigate and respond to consumer complaints • Lenders will need to move data internally to: • Interact with various complimentary/support utilities (compliance systems, doc prep, etc) • Interact with investor systems for loan delivery and other purposes

  7. TheRegulatory and Legislative Landscape • What will the new landscape hold ? • Change !! (Chaos?) • Some very safe predictions : • The R’s, particularly House R’s, will continue to meddle • The market structure WILL change (but how, and WHEN) • Regulators WILL get tougher, regardless of who that is • Existing agencies WILL continue to be very risk-averse • Pressure to improve process WILL NOT abate • Data, and its movement, WILL REMAIN VITAL

  8. TheRegulatory and Legislative Landscape Is Your Uniform Dirty?

  9. TheRegulatory and Legislative Landscape QUESTIONS

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