New and Revised Policy Templates for November 2017
This new product was developed in response to client requests who submitted their suggestions to our “Client Wish List.” Your comments and ideas are always greatly appreciated and will be taken into consideration whenever we revise our current products or create new ones. In summary, we want to ensure your success and earn your business!
The new Mortgage Loan Policy Template includes the complete contents of the following policy template products:
Mortgage Hedging Policy Template
Risk Management of Home Equity Lending Policy Template
Risk Management of Mortgage Fraud Policy Template
Risk Management of Non-Traditional Mortgage Products Policy Template
Risk Management of Sub-Prime Mortgage Lending Policy Template
Risk Management of Foreclosure Policy Template
The update to this product is in response to CFPB’s Consumer Protection Principles for Consumer-Authorized Financial Data Sharing and Aggregation issued on 10/18/17 that intends to reiterate the importance of consumer interests to all stakeholders in the developing market for services based on the consumer-authorized use of financial data. The Principles express the CFPB’s vision for realizing a robust, safe, and workable data aggregation market that gives consumers protection, usefulness, and value.
The update to these products is in response to CFPB’s Final Rule dated 10/05/17 that is aimed at stopping payday debt traps by requiring lenders to determine upfront whether people can afford to repay their loans. These strong, common-sense protections cover loans that require consumers to repay all or most of the debt at once, including payday loans, auto title loans, deposit advance products, and longer-term loans with balloon payments. The rule takes effect 21 months after it is published in the Federal Register, although the provisions that allow for registration of information systems take effect earlier.
As a reminder, the complete contents of the Payday, Vehicle, and High-Cost Installment Loan Policy Template are included within the Consumer Loan Policy Template as Topic 16 (formerly entitled “Short-Term and Small Dollar Loan Program”).
The update to this product is in response to OCC Bulletin 2017-43 entitled “New, Modified, or Expanded Bank Products and Services” dated 10/20/17 that informs financial institutions of the principles they should follow to prudently manage the risks associated with offering new, modified, or expanded products and services (collectively, new activities). In addition, the bulletin rescinds and replaces OCC Bulletin 2004-20, “Risk Management of New, Expanded, or Modified Bank Products and Services: Risk Management Process,” issued on May 10, 2004, and Office of Thrift Supervision Examination Handbook section 760, “New Activities and Services.”