The CFPB released additional compliance guides to assist small creditors in complying with the mortgage servicing rules under TILA and RESPA and the loan originator compensation rule finalized by the CFPB in January 2013 (see January 22, 2013 Alert). The guides are intended to be an "easy-to-use summary" of the rules and highlight issues that small creditors may face when implementing the rules. The guides also provide implementation and compliance considerations for small creditors. For example, the CFPB noted that when mapping out a compliance plan, in addition to the obligations under the rules, the compliance plan may: (1) identify affected products, departments and staff; (2) identify the business-process, operational and technology changes that will be necessary for compliance; (3) identify impacts on key service providers or business partners; and (4) identify training needs.
Alert June 11, 2013