Mortgage Compliance

Consumer Financial Protection Bureau Expands Complaint Reporting

Report to the CFPB
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Report to the CFPBThe CFPB has been reporting on consumer complaints for the past few tears, this is not new. However, they are now expanding this reporting to provide more specifics on the types of complaints received, and the companies receiving the most complaints (Complaints). You can read this article for all the gory details.

What does this mean for lenders? First and foremost, understand that if customers are not satisfied with the product and/or services received, they now have a public forum to voice their concerns. They have the option to have the details of their complaint against a lender published on the CFPB website for all to see. It doesn’t have to be fully factual.

The consumer can say just about anything about the lender, but the lender is limited in what can be disclosed in their response. Let’s face it, when other consumers see complaints about a lender, it will embolden them to come forward with more complaints, not necessarily justified in all cases. It also means that those lenders who may not be playing with a full deck could be easily exposed by multiple, similar complaints. Some good; some bad.

CFPB will monitor these complaints to determine the lenders which they may choose to audit and dig a little deeper into the basis and validity of the consumer complaints. It may not be as bad as everyone having cell phone video of a lender’s action to show on the nightly news, but it’s getting close. And, as it is in most cases today, the lender is considered guilty until they can prove their innocence. That may be very difficult.

So, lenders need to be aware that this is how it is. Consumer’s now have a public forum to take shots at lenders and lenders have very little they can do about it.

To avoid, or at least minimize, the harm, lenders need to be careful when doing their loans. Communication and documentation become critical. When CFPB comes knocking, a lender must be able to clearly indicate, explain and document all that was done to educate, instruct and service the consumer. Even then, it may still be a hard sell.

Like it or not, lenders have to face the fact that they are in the spotlight. It’s not all bad, as good lenders have a chance to shine, while those who give the industry a bad name may be exposed, and hopefully weeded out.

Make sure you’re one of those who sparkle. Do things right, for all the right reasons; because it’s the right thing to do. In doing so, you’ll not only benefit the consumer, but keep yourself out CFPB’s crosshairs.

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Michael Vitali

About the Author

Michael Vitali

Michael L. Vitali – Independent Consultant to the Mortgage Industry Mike Vitali is an independent consultant to the mortgage industry on matters concerning compliance and mortgage lending. He most recently served as the Senior Vice President and Chief Compliance Officer for LoanLogics, monitoring regulatory developments and their practical implications for the mortgage lending industry. His duties included research, interpretation, and analysis of existing and proposed legislation related to the industry in support of recommendations for policy and/or procedure changes to maintain continued quality and compliance with all applicable laws, rules and regulations, investor requirements, and standard mortgage practices. In his more than 40 years in the mortgage industry, in senior level management, he has gained experience in all areas of mortgage lending, risk management, and compliance. Mike is a past President of the MBA of Greater Philadelphia, is a charter member and was the second Chairman of the MBA of Pennsylvania, and a past board member and Legislative Chair of both associations. He is a recipient of the 1998 Mortgage Banker of the Year Award from the MBA of Greater Philadelphia, and the 2003 Chairman's Award from the MBA of PA, and currently serves on several compliance related task forces for MBA.
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Michael Vitali

About Michael Vitali

Michael L. Vitali – Independent Consultant to the Mortgage Industry Mike Vitali is an independent consultant to the mortgage industry on matters concerning compliance and mortgage lending. He most recently served as the Senior Vice President and Chief Compliance Officer for LoanLogics, monitoring regulatory developments and their practical implications for the mortgage lending industry. His duties included research, interpretation, and analysis of existing and proposed legislation related to the industry in support of recommendations for policy and/or procedure changes to maintain continued quality and compliance with all applicable laws, rules and regulations, investor requirements, and standard mortgage practices. In his more than 40 years in the mortgage industry, in senior level management, he has gained experience in all areas of mortgage lending, risk management, and compliance. Mike is a past President of the MBA of Greater Philadelphia, is a charter member and was the second Chairman of the MBA of Pennsylvania, and a past board member and Legislative Chair of both associations. He is a recipient of the 1998 Mortgage Banker of the Year Award from the MBA of Greater Philadelphia, and the 2003 Chairman's Award from the MBA of PA, and currently serves on several compliance related task forces for MBA.
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