CFPB Publishes Semi-Annual Rulemaking Agenda

On July 16, 2012 the CFPB published their CFPB Semiannual Regulatory Agenda 2012 Spring.   The agenda lists proposed and finalized rules.  Also included are rules classified as “prerule stage”  These are rules that:

(1) require registration of certain nonbanks, with an advance notice of proposed rulemaking (ANPRM) to be issued in January 2013,

(2) coordinating the supervisory authority of the CFPB and prudential regulators over depository institutions, with further action expected in September 2012, and

(3) addressing HMDA data collection requirements, with further action expected in April 2013.

The proposed rules include both those already issued and several that have not been issued.  On Servicing CFPB states that, in addition to implementing Dodd-Frank requirements, it “also is considering whether to propose additional requirements for early intervention and continuity of contact for troubled and delinquent borrowers, and for servicers to adopt reasonable information management policies and procedures.” The CFPB also notes that it is involved in an interagency process with other federal regulators “to consider broader issues regarding national servicing standards.”

The final category is long term actions.  The agenda includes 27 items, a clear indication that we will be busy with implementation of new requirements for a long time.