CFPB Released Memorandum of Understanding (MOU) with FRB, FDIC, NCUA, and OCC

The CFPB yesterdayeleased the attached a Memorandum of Understanding (MOU) with four other federal regulators (FRB, FDIC, NCUA, and OCC), clarifying how the agencies will coordinate their supervisory activities.  The MOU is dated May 16, 2012.

Section 1025 of the Dodd-Frank Act provides that the Consumer Financial Protection Bureau (CFPB) has exclusive authority to require reports and conduct periodic examinations relating to various consumer financial laws and issues, as to insured depository institutions and their affiliates with more than $10 billion in assets.  Similarly, section 1024 provides the CFPB comparable supervisory authority with respect to certain entities that are not insured depository institutions with total assets of $10 billion or more.

However, both sections also require that the CFPB work with the prudential regulators to: (1) coordinate the scheduling of examinations; (2) conduct simultaneous examinations of insured depository institutions with more than $10 billion in assets and their insured depository institution affiliates, unless the institution requests separate examinations; (3) share draft reports of examinations with the other supervising agency, and provide the receiving agency with opportunity to comment on the draft report before it is made final; and (4) take into consideration any concerns raised by the other agency before issuing the CFPB’s final report of examination.

Toward these ends, the regulators announced that, under the attached MOU, the agencies will work with each other and share materials concerning:


  • Compliance with federal consumer financial laws and certain other federal laws that regulate consumer financial products and services;
  •   Consumer compliance risk management programs;
  • Activities such as underwriting, sales, marketing, servicing, collections, if they are related to consumer financial products or services; and
  • Other related matters that the agencies may mutually agree upon.

According to the regulators, “[t]hese coordination undertakings should lead to greater uniformity and efficiencies in supervision and help to minimize regulatory burden on covered depository institutions.”

Copy of MOU attached  MOU – Supervision – CFPB, OCC, NCUA, FRB and FDIC

A Good Time to Buy a House – American Respond

Nearly three-quarters of Americans said they thought it was a good time to buy a home last month, with expectations that rental and purchase prices will rise over the next year and as consumers’ views of their finances stabilized, according to a monthly survey by mortgage finance company Fannie Mae (FNMA).

“Conditions are coming together to encourage people to want to buy homes,” said Doug Duncan, Fannie Mae chief economist.

The portion of Americans who indicated that it is a good time to buy in March–73%–was up 3 percentage points. The percentage of those who said it is a good time to sell was up by 1 percentage point at 14%.

The portion of participants who expected home prices to increase over the next 12 months improved to a third last month, from 28%. On average, consumers expected U.S. home prices to increase 0.9%.

A record 49% of respondents expected rental prices to increase, the highest number since Fannie Mae began tracking the metric in June 2010. On average, consumers expected rents to rise 4.1%.

Also, more respondents expect that mortgage rates–currently around historic lows–will increase over the next year: at 39%, up by 5 percentage points.

The percentage of respondents that expect their financial situation will worsen over the next year was 12%, consistent with February as the lowest value in more than a year and tied with January for the lowest to date.

The portion of respondents whose income increased significantly from a year earlier was 21%, an improvement of 1 percentage point. Meanwhile, 63% reported that their income stayed the same, consistent with February data.

February 2012 U.S. Foreclosure Market Report: Foreclosure Tide Rising in Half of Largest Metro Areas

March 15, 2012 — RealtyTrac® (, the leading online marketplace for foreclosure properties, today released its U.S. Foreclosure Market Report™ for February 2012, which shows foreclosure filings — default notices, scheduled auctions and bank repossessions — were reported on 206,900 U.S. properties in February. That was a 2 percent decrease from the previous month and was down 8 percent from February 2011 — the lowest annual decrease since October 2010. The report also shows one in every 637 U.S. housing units with a foreclosure filing during the month.

“February’s numbers point to a gradually rising foreclosure tide as some of the barriers that have been holding back foreclosures are removed,” said Brandon Moore, CEO of RealtyTrac. “Although national foreclosure activity was pushed lower by decreases in a handful of larger states, 21 states posted annual increases in foreclosure activity, the most states with annual increases since November 2010.

“The foreclosure and mortgage settlement filed in court earlier this week will help pave the way to a properly functioning foreclosure process by providing a clear roadmap for necessary foreclosures,” Moore continued. “That should result in more states posting annual increases in the coming months. Not surprisingly, many of the biggest annual increases in February were in states with the more bureaucratic judicial foreclosure process, which resulted in a larger backlog of foreclosures built up over the last 18 months in those states.”

What Does $448 Million Get You? A Whole Lot of CFPB

As the CFPB gets its feet wet in monitoring and enforcing consumer financial protections, it has come under examination on another front: how much it costs.

CFPB Director Richard Cordray presented testimony last Wednesday before members of a House Financial Services subcommittee in defense of the CFPB’s increasing price tag for taxpayers. According to the Administration’s latest budget proposal released Monday, the cost of the agency will amount to $448 million in 2013. Because it is not subject to the congressional appropriations process, it also has the ability to request more.

See below for the breakdown of the CFPB Budget.