The just released 2013 CFPB Dodd-Frank Mortgage Rules Readiness Guide (Guide) from the Consumer Financial Protection Bureau (CFPB) provides, finally, a set of criteria and preparation procedures for residential mortgage lenders and originators. It is Version 1.0 and, like previously issued guides and manuals, the CFPB will update the Guide periodically, using the results from its field examinations to further enhance the audit methodologies.

  

Note that it is called a Readiness Guide. Such documents are not meant to be, and are not, conclusive. These guides are expected to be sign posts leading the way, a means by which a company may learn of the priorities and exigencies of a regulator's oversight functions. In other words, as the Guide itself declaims: "The Guide summarizes the mortgage rules finalized by the CFPB in January 2013, but it is not a substitute for the rules."

  

To put a finer point on the use of the Guide, please always remember that only the rules and their official interpretations can provide complete and definitive information regarding their requirements.

  

In this article, I will offer an overview of the new Guide, including some suggestions to implement the self-assessment and the elements of a viable readiness review.

  

Best wishes,
Jonathan

  

  

Version 1.0

July 1, 2013

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