Director Cordray mostly repeated previous comments in his remarks this week at the Mortgage Bankers Association Annual Convention in Washington, DC.
The first portion of Director Cordray’s remarks followed his usual script, outlining the history of the financial collapse, Dodd-Frank, and the start of the CFPB. From there, he explained how the CFPB took into account input from the industry in drafting and revising the new mortgage rules, focusing on “open, inclusive, transparent decision-making.”
While Director Cordray appears to remain unwilling to delay the mortgage rules’ effective date, he did reiterate the CFPB’s intention to be reasonable in enforcement when a company makes a good faith effort to comply with the new rules. Copying almost verbatim from remarks given at the American Bankers Association’s Annual Convention on October 21, Director Cordray told the mortgage industry that “our oversight of the new mortgage rules in the early months will be sensitive to the progress made by those lenders and servicers who have been squarely focused on making good-faith efforts to come into substantial compliance on time – a point that we have also been discussing with our fellow regulators.” As we stated in our post covering Director Cordray’s remarks at the ABA Convention, private plaintiffs likely will not be so indulgent.
Director Cordray notably did not remark on the progress in drafting the TILA-RESPA Integrated Disclosures Final Rule. Although the CFPB had previously indicated that we can expect the rule before the end of the year, it is unclear whether that is still true.
