Editor: David Reiss
Brooklyn Law School

November 30, 2015

The Semi-State of the CFPB

By David Reiss

Cordray Speech

The Consumer Financial Protection Bureau released its Semi-Annual Report for the period ending September 30th. I think that it is a dog-bites-man type of report as far as mortgages are concerned. A lot of the heavy lifting on mortgages has already been done over the last few years with the issuance of various major rules, although the Bureau did issue a lot of proposed mortgage rules with smaller scopes during this period (see pages 89-90).  The Bureau now seems to be mostly in an enforcement mode as far as mortgages are concerned (see pages 103-119 for an overview of 45 recent enforcement actions). The report also provides pretty comprehensive lists of its significant activities in its appendices:

  • Appendix B:  Statutory reporting requirements
  • Appendix C:  Significant rules, orders, and initiatives
  • Appendix D:  Actions taken regarding rules, orders, and supervisory actions with respect to covered persons which are not credit unions or depository institutions
  • Appendix E:  Significant state attorney general and regulator actions
  • Appendix F:  Reports
  • Appendix G:  Congressional testimony
  • Appendix H:  Speeches

I leave you with an interesting chart from the report:

Types of Mortgage Complaints (from about 50,000 total)                           %

  • Problems when you are unable to pay (e.g., foreclosure)  45%
  • Making payments (e.g., loan servicing)  37%
  • Applying for the loan (e.g., mortgage broker)  9%
  • Signing the agreement (Settlement process and costs)  5%
  • Receiving a credit offer (Credit decision/Underwriting)  3%
  • Other  2%

Total mortgage complaints                                                                    100%

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