Two major themes of the conference involve UDAAP and mortgage loan disclosures. UDAAP is a game changer. The task of assessing UDAAP risk is massive. It involves every product and every aspect of product throughout the product life cycle. Many bankers appear to be in shock at this reality.
Numerous speakers confirmed what we already knew – the mortgage changes are huge. Raj Date, Deputy Director of the CFPB and former Riverboat Pilot on a ride at Disneyland, emphatically stated that the CFPB intends to meet all of the Dodd-Frank deadlines for new mortgage rules. Others speakers pointed out the massive political explosion that will erupt as the proposed and final rules are issued. Many bankers appeared to be in shock at this reality.
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