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Jul. 8, 2011: CFPB update; implementing best secondary practices
Rob Chrisman
[This is
the last day for quite some time that I am away from the
computer on a daily basis. This is the last guest writer spot,
and I very much appreciate the time and effort that the
contributors put forth. As I have mentioned, I gave them very
little direction, and they rose to the occasion. Our views may
or may not coincide, but once again I thank them for their time
in volunteering and helping out.]
A talent for writing
runs in my family, as does musical aptitude. Disappointingly,
both talents widely dodged me and I am left instead to merely
stake my claim as the tallest of the Farmer clan (locally, of
course.) Since my lofty stature is not particularly useful to me
as guest writer for the Chrisman letter; forgive me if I borrow
the writing talent from others. But first, I really have to give
kudos to Rob for the fine work he does. It is a tremendous
challenge to come up with stimulating material on just a
‘one-off’ basis, doing this daily is beyond my comprehension.
Casey Anthony… I’m a
little late to the story and don’t have anything to say about
her trial that hasn’t been said, but I was worried that not
mentioning her case would render my contribution irrelevant. In
googling
mortgage industry with Casey
Anthony Trial, I discovered that Frank
Hilliard does have an opinion, albeit, one he describes
as, “probably very unpopular.” I’ve heard comparisons of this
trial to the O.J. affair, but only in its ‘shocking’ verdict and
massive media coverage. The Anthony trial does not seem to
engender social divisions the way the O.J. trial reactions often
split along racial lines.
Mortgage bankers have
had tremendous change thrust upon them in recent years. New
regulations applied (RESPA, HVCC, TILA, SAFE Act, etc.) have
typically required the development and deployment of new
operating processes, investments in new (or upgraded)
technologies, additional headcount, and ultimately, higher costs
and reduced margins for the mortgage banker. While bankers
search for the right tools and the right policies to achieve the
most favorable balance between rate competitiveness and
compliance with the new regulations, most agree that these
changes will present additional challenges to their
profitability. For many bankers, a secondary process that fully
leverages the secondary mortgage market for additional
profitability is no longer just a “nice-to-have,” but rather the
new imperative for success. Read more on implementing best
secondary practices in this White
Paper. (Full Disclosure: MCT President, Curtis Richins,
wrote the linked document as commissioned by NYLX. It is both
useful and informative.)
With all the changes
in our industry, it is comforting to note that we are not alone
in our need to adapt. Consider the current NFL negotiations on
changes to revenue sharing, salary caps, and other points of
interest. Sam Farmer, Los Angeles Times NFL Columnist (my
younger brother and recipient of all the writing talent in his
Farmer generation,) provides a solid Q&A
on the current state of negotiations, predictions on timing, and
perspective on the winners/losers. One similarity I see between
the football and the mortgage lending industries is the
resilience that both demonstrate in finding paths across
seemingly impassable chasms.
The Consumer
Financial Protection Bureau (CFPB) has about 35 openings
across offices in D.C., Chicago, NYC, and San Francisco. (And
Rob gives an update – see the bottom paragraph.) The salaries
are higher than I expected. Here is one in New York (2
openings.)
Supervisory
Examiner, Assistant Regional Director
CLOSES JULY 29, 2011
GRADE
7A $142,443 - $264,803
Open to candidates
with permanent competitive service status, non-competitive
eligibles, and special appointment eligibles.
It looks like the
life of a civil servant is becoming more desirable. NOTE: I
don’t know any details other than those on the site.
While on the topic,
the CFPB received substantial response to the two latest
combined TIL/GFE prototype forms; Redbud
and Dogwood.
The two prototypes make identical presentations of loan terms,
projected payments, and comparisons but differ substantially in
the manner in which they present loan estimate details. The
first request for feedback on the initial prototypes received in
excess of 13,000 responses. No definitive number on the most
recent round for input that closed July 5th. Which do
you prefer and why? Here is a letter
from the MBA to Elizabeth Warren, Assistant to the President and
Special Advisor to the Treasury Secretary (CFPB Chief),
appreciating improvement over the last prototype and expressing
continuing concerns on the new drafts.
Since Rob is in
Europe, I thought it might be appropriate to share a European
perspective on Americans and our culture. This is a pretty
tight summary!
Thomas P. Farmer
MCT, Inc.
tfarmer@mctrade.net
(619) 543-5111 main
(619) 534-1597
If you're interested,
visit Rob’s twice-a-month blog at the STRATMOR Group web site
located at
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