After the Consumer Financial Protection Bureau proposed a much anticipated set of new rules for mortgage servicers Friday, a lot of work remains.
The American Bankers Association put together a handy chart for pending Dodd-Frank mortgage reform. Three rules are already out for comment: the RESPA-TILA form merger, provisions for determining “high-cost” loans and the servicing guidelines.
August, however, will be busy. (Click on the chart below to expand.)
The bureau will propose clarifications to the Fed’s loan officer compensation rule, and the Fed itself is set to release appraisal reforms, which the ABA notes will likely include mandatory property visits and new requirements for even more appraiser independence. Much of the appraisal industry remains unregulated even after some Dodd-Frank rules set new standards in place.
The bureau itself will get in on adjusting appraisal rules to make sure borrowers get a free copy of any appraisal report referenced at least three days prior to closing on a new loan.
Even further out on the horizon are even larger changes, including the finalized risk-retention rule (for which the comment period ended in August) and what a qualified mortgage will look like. These two rules will effectively set the mortgage market for decades to come.
Dodd-Frank requires most of these to be finalized by Jan. 21. If not, many will go into effect right away. The CFPB noted in its servicing rules released Friday that it wants to avoid that, so it will build in implementation deadlines for several of the rules in the months after finalizing them.
Even further out is GSE reform, but as long as Washington remains gridlocked and the GSEs start to earn profits again, it’s not even worth putting on a calendar.
