Pub. 4 2014-2015 Issue 1

8 O V E R A C E N T U R Y : B U I L D I N G B E T T E R B A N K S - H E L P I N G C O L O R A D A N S R E A L I Z E D R E A M S FEATURE ARTICLE “Many compliance specialists often argued that because trusts, are not defined as “natural persons,” a loan to such an entity would be exempt from the regulation.” R emember back in 2012 when the CFPB proposed the “Integrated Mortgage Dis- closures”? This rule requiring the Know- before–you-Owe disclosures was touted by many as the perfect marriage of TILA and RESPA. Before we buy into that description, let’s take a deeper dive into exactly what changes are found buried within the 1,888 pages of expla- nations, requirements and model disclosures. The CFPB received over 3,000 comments when the rule was first proposed. The CFPB expected this type of reaction because of the significant changes. The new requirements not only affect two major regulations, they also af- fect the entire residential real estate industry. The CFPB responded to the comments by adding over 750 pages to the regulation, bringing the total to 1,888 pages for this amendment alone. Of course the agency is justifying these changes by stating that the actual regulatory changes only accounts for 70 pages, bringing the total to 279 pages in length. By any standard, that is a lot of in- formation to digest and implement. Ah, I digress. Let’s put these facts out of our mind and move on to what this actually means to us as bankers. DARLIA FOGARTY DIRECTOR OF COMPLIANCE AND DIMITRIS ROUSSEAS ASSOCIATION GENERAL COUNSEL RESPA/TILA Reform - Through Mortgage Disclosure Integration