I could tell that my cat Myrtle was miffed. Not only had the work on her “2024 Vision Board Statement” languished, but either there was no line-caught halibut in her bowl, or the laser pointer’s battery was dead. It turned out that it was neither. Instead, it was news that the CFPB was not meeting its goals. the Office of Inspector General of the Federal Reserve Board released a report assessing the CFPB’s process for conducting enforcement investigations and making two recommendations. First, noting that the CFPB has not met its stated goal to file or settle 65 percent of its enforcement actions within two years, the OIG recommended that the CFPB Office of Enforcement incorporates the timing expectations for key steps in the enforcement process into the tracking and monitoring of matters. The OIG also recommended improvements to enforcement staff training on document maintenance and retention requirements for the CFPB’s matter management system. The
Every lender or investor with an “a” in their name seems to be subject to rumors and news in recent months. (More on Flagstar and American Pacific below.) Know anyone named “Bernadette”? The name is actually Latin for, “The act of torching a mortgage.” (Yes, it is cutting edge humor like that which brings you back.) Burning liens isn’t a topic, but paying them off early is, and with mortgage rates off of their highs, early pay offs, or EPOs, were a conversation topic at the conference this week. And with it, loan officer compensation follows. Can a lender pay an originator based on pull through? Yes. Can lenders pay different originators under different payment plans, as long as the originator sticks with one plan? Yes. Can a lender, if they comply with state labor law, ask for compensation back after an EPO or EPD? Yes, and it may depend on the contract signed by both parties at the beginning of employment. As always, consult your in-ho