Cfpb agency servicestoolkit-fordistribution
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Agency Services CFPB Toolkit
How am I going to learn CFPB?…..”CFPB 101”
Introducing…..
Agency Services CFPB ToolkitThe complete resource that contains everything needed to establish you and Stewart as the CFPB “go to” resource with our independent agencies.
The Toolkit includes everything needed for you to provide both group and one-on-one presentations on the topic of CFPB requirements for service providers. When giving those presentations, you will also be able to share exciting news about the Stewart Trusted Provider CFPB Toolkit for our independent agencies to use in marketing to both Lenders and REALTORS® in their local markets.
Agency Services CFPB Toolkit
• Marketing Plan• CFPB 101 Quick Start• Handouts• Flyers• Emails• Invitations• Presentations• Checklists
Stewart Trusted Provider CFPB Toolkit
• Marketing Plan• CFPB 101 Quick Start• Handouts• Flyers• Emails• Invitations• Presentations• Checklists
Available Today
Coming Soon!!
*Available on Stewartmarketing.com
Agency Services AssociatesYou recently received an email with the announcement shown at the right providing highlights of this marketing program.
This effort is patterned after the successful “CFPB Seminar-in-a-Box” program used by direct operations. With Stewart associates having presented at more than 500 events – the success continues. Just like the effort in direct operations, your events and success stories will soon be tracked in CRM with reports going to the District Managers and George Houghton. The idea is to present to agencies “one-on-one” in their offices during quarterly visits.
As you view this presentation, note that the slides shown as “Backstage” contain information for you about the program and presentations that you will give to the Stewart agencies. Portions of the presentation (slides 9 – 34) featuring Stewart’s lighthouse theme contain the “script” that you will use when presenting to your agencies. We’ve included speaker notes allowing flexibility in length of presentation since both ‘basic’ and ‘extended’ information is included. Longer presentation? No problem, just include the extended information following the basic.
Finally, toward the end of the presentation (slides 35-52) will be a review of the “private label” CFPB presentation that will be available to Stewart agencies for providing CFPB updates and marketing their Trusted Provider status to REALTORS® and Lenders in their local markets. These Powerpoint slides are easy to spot as they are “private label” and include the Trusted Provider logo at the bottom.
Next Steps and Additional Information1. Watch Video
a) View this complete video and take notes. Write down any questions or concerns you may haveb) NOTE: If you have not watched the video, do so today!!
2. Review Recorded Discussion WebEx Conference Calla) On February 25th or 26th, Marvin Stone and George Houghton hosted a Discussion WebEx Conference Call. Watch the recorded
version as a reminder of the information you need to remember when presenting to your agenciesb) Direct any questions you may have to your District Manager
3. Continue the Train-the-Trainer dialoguea) The video and the recorded WebEx session will constitute most of the trainingb) Your District Manager and Executive Management are fully aware of your time constraintsc) Continue to provide suggested improvements for the Toolkit and FAQ’s, CFPB Questions, See Escalation Path (below), etc
4. Escalation Path for Questions or Suggestions for Improvementa) ASM/ASR > DM > Gloria Prinz > George Houghton/Pat Beall cc: Marvin Stone
5. Promote the Stewart Trusted Provider Presentationa) The Trusted Provider CFPB Toolkit Presentation was created for your independent agencies to present to their REALTOR® and
Lender customers. It’s a locked-down PDF presentation with a place for your independent agencies to add their company logob) Have your agent present on their own or you can partner with your agent to present to their customers
6. TIPS/Agency Conference Mentionsa) News, current events, high-level info > call to action (workshop)
The “Real World” Timeline for Lenders
About the PowerPoint The following PowerPoint presentation has been designed to make it easy for you, the Stewart Agency Services associate, to give a CFPB update of varying lengths depending upon the audience and time allotted.
The speaker notes are provided in “Basic” and “Expanded” sections. Cover the Basic section in your own words in each presentation – then continue talking through the Expanded section if time is available or if the subject matter is of greater interest to your current audience. Practice to understand the impact that adding the Expanded notes will have upon the length of the presentation.
9
CFPB Updatefor
[Insert ASM/ASR Name]
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
10© Copyright Stewart 2014
History of the CFPB
CFPB formed with Richard Cordray as Director Supervisory authority over Banks and Non-Banks. Enforcement authority over RESPA and TILA
-
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
11© Copyright Stewart 2014
DisclosuresMeet CFPB and lender requirements:1.Produce for or by settlement2.Lender delivery – or –3.Settlement delivery4.Unroll Title Services Fees5.Prepare for 3-Day Rule6.Understand Tolerances7.Prepare for Trial Period
ControlsMeet requirements of the following:1.ALTA Best Practices2.CFPB Service Provider Bulletin3.OCC Bulletin on Third-Parties4.FDIC Bulletin on Third Parties5.Fourth-party risk
ComplaintsImprove Documented Process for:1.Consumer complaints2.State regulator complaints3.CFPB complaints database4.Lender requirements
TransformationChange the closing process to:1.Reduce number of disclosures2.Ensure accurate quotes3.Deliver docs earlier 4.Educate consumers
2 3 41
Areas of Focus
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
12© Copyright Stewart 2014
CFPB Finalizes Rule on Integrated Disclosures
Better Disclosures
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
13© Copyright Stewart 2014
Closing Disclosure for Purchase
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
14© Copyright Stewart 2014
Service Provider “flight to quality”
CFPB Bulletin to Banks and Non-Banks stating they must use quality service providers.
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
15© Copyright Stewart 2014
Service Provider “flight to quality”
Other regulators restating their requirements for “third-party risk”
Federal ReserveFDICOCCFFIEC
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
16© Copyright Stewart 2014
Service Provider “flight to quality”
1. Current Licenses - Establish and maintain current License(s) as required to conduct the business of title insurance and settlement services.
2. Escrow Accounts - Adopt and maintain appropriate written procedures and controls for Escrow Trust Accounts allowing for electronic verification of reconciliation.
3. Privacy Program- Adopt and maintain a written privacy and information security program to protect Non-public Personal Information as required by local, state and federal law.
4. Settlement Procedures- Adopt standard real estate settlement procedures and policies that help ensure compliance with Federal and State Consumer Financial Laws as applicable to the Settlement process.
5. Title Procedures - Adopt and maintain written procedures related to title policy production, delivery, reporting and premium remittance.
6. Insurance Coverage - Maintain appropriate professional liability insurance and fidelity coverage.
7. Complaints Process - Adopt and maintain written procedures for resolving consumer complaints.
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
17© Copyright Stewart 2014
Stewart Trusted Provider Policy TemplatesSample
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
18© Copyright Stewart 2014
Stewart Trusted Provider Policy TemplatesPolicies and procedures for your agency to customize and deploy for a compliance quick start
1.Account Management Policy
2.Acknowledge Receipt of Policies
3.Anti-Fraud – Corruption Policy
4.Anti-Virus Malware Policy
5.Application Security Policy
6.Background Investigations Policy
7.Backup and Media Retention Policy
8.Business Continuity Plan Template
9.Business Continuity Policy
10.Business Continuity Prep/Response Plan
11.Customer Complaint Tracking Form
12.Customer Complaint Policy
13.Data Retention Policy
14.External Audits Policy
15.Fair Lending Compliance Policy
16.Foreign Corrupt Practices Act Offshore Tasks Policy
17. Instant Messaging Policy
18. IT Security and Computer Usage Policy
19. Managing Exceptions Policy
20. Managing Exceptions Process
21. Mobile Devices Policy
22. Non-Public Information Security & Disposal Policy
23. Notary Services Policy
24. Password Policy
25. Policy Exception Request Form
26. Privacy & Information Security Audit/Oversight Policy
27 Remote Access Policy
28 Security Incident Response Policy
29. Security Training and Awareness Policy
30. Social Media Policy
31. Standards of Conduct Policy
32. Title Insurance and Settlement Services Policy
(Bold indicates new releases in October 2013)
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
19© Copyright Stewart 2014
Stewart’s Approach to Due Diligence & Monitoring
Initial Due DiligenceIndependent pre-sign audit by Deloitte
Thorough background and credit checks
Examination of applicant’s business model
Review of applicant’s policy loss history
Verification of licensing
On-going Monitoring•Regular Deloitte audits based on risk
•Quarterly on-site visits
•Quarterly operational checks
•Policy inventory audits
•Comprehensive operational review
•Title/settlement loss prevention training
•Regulatory compliance training
•Random background and credit checks
•License verification
•Review of E&O / fidelity bonds
•Agency validation web service*
In the United States, Deloitte LLP and its subsidiaries have more than 57,000 professionals dedicated to providing audit, consulting, financial advisory, risk management and tax services to selected clients. With over 100 years of history and a global network of highly-trained professionals, Deloitte is a trusted partner to the top names in financial services
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
20© Copyright Stewart 2014
Stewart Trusted Provider Program
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
21© Copyright Stewart 2014
Memorialized Due Diligence Response
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
22© Copyright Stewart 2014
Complaints
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
23© Copyright Stewart 2014
Complaints
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
24© Copyright Stewart 2014
Complaints
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
25© Copyright Stewart 2014
Stewart Trusted Provider Policy Templates
Sample
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
26© Copyright Stewart 2014
Transforming the Closing Process
“So as part of our “Know Before You Owe” initiative, we are making a commitment to work with industry to improve the mortgage closing experience for consumers through technology. We believe that “eClosings” could represent a positive development along these lines, and we want to know more about how we can foster innovation in this area.
CFPB Director Richard CordrayBoston Field Hearing,November 20, 2013
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
27© Copyright Stewart 2014
Transforming the Closing Process
Five major goals in this new initiative:
1.Create efficiency with technology
2.Reduce the number of disclosures
3.Ensure the accuracy of up-front quotes
4.Deliver docs earlier in the process
5.Educate the consumer
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
28© Copyright Stewart 2014
Resources
stewart.com/cfpbService Provider Memo
ALTA Best Practices
QM / ATR
Integrated Disclosures
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
29© Copyright Stewart 2014
Stewart Trusted Provider Seal
Show Lenders, REALTORS®, Consumers and Business Partners YOU are the agency they need to work with
You’ve been vetted and verified by: Passing an intensive due-diligence screening Conducting business according to our stringent Independent Agency
Standards Undergoing strict ongoing monitoring
You’re a trusted provider of real estate settlement services Add the seal to your website, email signature and marketing collateral Visit stewart.com/agencytrust
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
30© Copyright Stewart 2014
Stewart Trusted Provider Seal with ESB
With a Stewart Escrow Security Bond (ESB), you’re a Trusted Provider with even more security
An ESB, underwritten by Lloyd’s of London®, may provide settlement fund recovery as a result of fraudulent activities, including:
Computer crime rider Cyber liability – Consumer data security Employee theft coverage Partner/principal theft coverage Embezzlement Payable fraud Receivable fraud Diversion schemes Fictitious write-offs Expense schemes
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
31© Copyright Stewart 2014
Marketing at its Best
Samples Emails
Flyers
Drop Cards
eCards
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
32© Copyright Stewart 2014
Next Steps
Follow CFPB news and updates on Stewart.com/cfpb
Leverage the Stewart Trusted Provider Policy Templates
Regularly attend the Stewart Agency Services webinars
Refine your consumer complaints process Implement the Stewart Trusted Provider CFPB
Toolkit Ensure your buyers and lenders are protected by
Stewart
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
33© Copyright Stewart 2014
Q&A
- About the CFPB
- Effective Date
- Loan Estimate
- Closing Disclosure
- Delivery Alternatives
- Three-Day Rule
- All-In APR
- Electronic Storage
- Proposals Not Adopted
Today’s Topics
- History of the CFPB
- Areas of Focus
- Disclosures
- Controls
- Complaints
- Transformation
- Trusted Provider Toolkit
- Next Steps
- Q & A
34© Copyright Stewart 2014
Thank You
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