CFPB Plans Further Servicing Rules Updates

Investor Update
May 20, 2016

The Consumer Financial Protection Bureau (CFPB) announced on Friday the implementation of new mortgage servicing rules and new rules related to the Know Before You Owe (TRID) rule as part of its semiannual Spring 2016 rulemaking agenda.

The CFPB said it expects to issue a final rule in the summer to amend a proposal it originally made in December 2014 to amend the mortgage servicing rules that originally took effect in 2013.

“The proposal addressed, among other things, enhanced loss mitigation requirements and compliance with certain rules when the borrower is a potential or confirmed successor in interest or is in bankruptcy,” the CFPB said. “We conducted testing of periodic statements for consumers in bankruptcy and published the testing report for comment in April 2016.”

In addition to the new mortgage servicing rule, the CFPB said it expects to release a Notice of Proposed rulemaking in order to provide some clarification and further regulatory guidance concerning the TILA-RESPA Integrated Disclosure (TRID) rule, also known as the Know Before You Owe mortgage initiative, which was implemented on October 3, 2015. In late April, CFPB Director Richard Cordray wrote a letter to financial industry trades and their members recognizing the “operational challenges” the industry is experiencing as a result TRID implementation and that the Bureau is considering making some “adjustments” in the regulation text to provide greater certainty and clarity.

According to the CFPB, the Bureau is continuing other efforts to implement critical consumer protections under Dodd-Frank to guard against the practices in the mortgage market that were the biggest contributors to the 2008 mortgage crisis.

“Since 2013, the Bureau has issued regulations as directed by the Dodd-Frank Act to implement certain protections for mortgage originations and servicing, integrate various federal mortgage disclosures, and amend mortgage reporting requirements under the Home Mortgage Disclosure Act (HMDA),” the CFPB said. “The Bureau is continuing intensive work to facilitate implementation of the new requirements, including follow-up rulemaking where warranted.”

Specifically, the CFPB is “intensely” planning the implementation of the rule (finalized in October 2015) to implement Dodd-Frank amendments to the Home Mortgage Disclosure Act (HMDA). An entity compliance guide has already been released in connection with the rule; and while certain elements of the rule are scheduled to take effect in January 2017, most of the new data collection requirements are scheduled to take effect in January 2018.

“The Bureau is also working to streamline and modernize the HMDA data reporting processes in conjunction with implementation of the regulatory changes, and is conducting outreach with industry to prepare for both the regulatory and operational changes,” the CFPB said.

Click here to view the complete agenda.

Source: DS News

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CEO

Alan Jaffa

Alan Jaffa is the Chief Executive Officer for Safeguard Properties, steering the company as the mortgage field services industry leader. He also serves on the board of advisors for SCG Partners, a middle-market private equity fund focused on diversifying and expanding Safeguard Properties’ business model into complimentary markets.

Alan joined Safeguard in 1995, learning the business from the ground up. He was promoted to Chief Operating Officer in 2002, and was named CEO in May 2010. His hands-on experience has given him unique insights as a leader to innovate, improve and strengthen Safeguard’s processes to assure that the company adheres to the highest standards of quality and customer service.

Under Alan’s leadership, Safeguard has grown significantly with strategies that have included new and expanded services, technology investments that deliver higher quality and greater efficiency to clients, and strategic acquisitions. He takes a team approach to process improvement, involving staff at all levels of the organization to address issues, brainstorm solutions, and identify new and better ways to serve clients.

In 2008, Alan was recognized by Crain’s Cleveland Business in its annual “40-Under-40” profile of young leaders. He also was named a NEO Ernst & Young Entrepreneur Of The Year® Award finalist in 2013.

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Esq., General Counsel and EVP

Linda Erkkila

Linda Erkkila is the General Counsel and Executive Vice President for Safeguard Properties, with oversight of legal, human resources, training, and compliance. Linda’s broad scope of oversight covers regulatory issues that impact Safeguard’s operations, risk mitigation, strategic planning, human resources and training initiatives, compliance, insurance, litigation and claims management, and counsel related to mergers, acquisition and joint ventures.

Linda assures that Safeguard’s strategic initiatives align with its resources, leverage opportunities across the company, and contemplate compliance mandates. She has practiced law for 25 years and her experience, both as outside and in-house counsel, covers a wide range of corporate matters, including regulatory disclosure, corporate governance compliance, risk assessment, compensation and benefits, litigation management, and mergers and acquisitions.

Linda earned her JD at Cleveland-Marshall College of Law. She holds a degree in economics from Miami University and an MBA. Linda was previously named as both a “Woman of Influence” by HousingWire and as a “Leading Lady” by MReport.

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COO

Michael Greenbaum

Michael Greenbaum is the Chief Operating Officer of Safeguard Properties, where he has played a pivotal role since joining the company in July 2010. Initially brought on as Vice President of REO, Mike’s exceptional leadership and strategic vision quickly propelled him to Vice President of Operations in 2013, and ultimately to COO in 2015. Over his 14-year tenure at Safeguard, Mike has been instrumental in driving change and fostering innovation within the Property Preservation sector, consistently delivering excellence and becoming a trusted partner to clients and investors.

A distinguished graduate of the United States Military Academy at West Point, Mike earned a degree in Quantitative Economics. Following his graduation, he served in the U.S. Army’s Ordnance Branch, where he specialized in supply chain management. Before his tenure at Safeguard, Mike honed his expertise by managing global supply chains for 13 years, leveraging his military and civilian experience to lead with precision and efficacy.

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CFO

Joe Iafigliola

Joe Iafigliola is the Chief Financial Officer for Safeguard Properties. Joe is responsible for the Control, Quality Assurance, Business Development, Marketing, Accounting, and Information Security departments. At the core of his responsibilities is the drive to ensure that Safeguard’s focus remains rooted in Customer Service = Resolution. Through his executive leadership role, he actively supports SGPNOW.com, an on-demand service geared towards real estate and property management professionals as well as individual home owners in need of inspection and property preservation services. Joe is also an integral force behind Compliance Connections, a branch of Safeguard Properties that allows code enforcement professionals to report violations at properties that can then be addressed by the Safeguard vendor network. Compliance Connections also researches and shares vacant property ordinance information with Safeguard clients.

Joe has an MBA from The Weatherhead School of Management at Case Western Reserve University, is a Certified Management Accountant (CMA), and holds a bachelor’s degree from The Ohio State University’s Honors Accounting program.

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Business Development

Carrie Tackett

Business Development Safeguard Properties