CFPB Postpones Mortgage Disclosure Effective Date

June 18, 2015 at 8:38 am Leave a comment


I have some good news this morning.  CFPB Director Richard Cordray announced yesterday that the Bureau was moving back the effective date of the integrated disclosure mortgage requirements from August 1st to October 1. (  The announcement comes after the Bureau had steadfastly resisted increasingly desperate  calls from Congress and industry stakeholders to delay the effective date.  In its  statement, the Bureau explained that it was proposing the new effective date after discovering an administrative error that would have resulted in a two week delay in implementing the regulation.

The  integrated disclosure rules  require that  closing disclosures be received by a home buyer three business days before a mortgage loan is “consummated.” The  two month delay gives credit unions more time to prepare for these changes and it also  gives us more time to  clarify a core concern of New York credit unions: When a loan is considered “consummated” for purposes of NYS law.  Stay tuned.

FED Holds Its Fire On Rate Hike…For Now

Even as it sees signs of an economy growing at a moderate pace, the Fed decided yesterday not to raise short-term interest rates. Instead it  stressed, to the extent that it publicly stresses anything, that it will probably raise rates by the end of the year.  It also is continuing to rollover its existing portfolio of  Mortgage Backed Securities it purchased during its period of Quantitative Easing. (

If you are hoping for a reprieve from those razor-thin Net interest Margins don’t hold your breath. And remember,  this period of historically low rates comes as  the Bureau is expected to propose restrictions on overdraft fees in the coming months.  Yes,  expect running a credit union to be as challenging as ever.

One more depressing thought: This recovery, as anemic as it is, can’t last forever.  What would the Fed or a divided Congress be able to do to fight another downturn?     As the Economist pointed out in a recent editorial the economic recovery is entering its sixth year and if another contraction occurs, as a result of a Greek Default for example:

“Rarely have so many large economies been so ill-equipped to manage a recession, whatever its provenance… Rich countries’ average debt-to-GDP ratio has risen by about 50% since 2007. In Britain and Spain debt has more than doubled. Nobody knows where the ceiling is, but governments that want to splurge will have to win over jumpy electorates as well as nervous creditors.” (

Move Over Alex

Alexander Hamilton, the nation’s first Treasury Secretary, will have to share space on the $10 bill with a yet unnamed woman.  The Treasury announced that, starting in 2020,  it will either start issuing some bills with Hamilton on one side and the unnamed matriarch on the other or a mix of bills, some with Hamilton and some with his female counterpart.  My vote would be Maria Reynolds who would serve as a reminder that our politicians haven’t changed as much as we think we have and yet we managed to grow into a great country.

As explained in this Huffington Post Blog from 2011:

“In the summer of 1791, Hamilton was the target of what a modern-day espionage novel would call a “honey trap,” set by a blonde 23-year-old named Maria Reynolds. Hamilton then became the target of outright blackmail, by the woman’s husband (who was quite likely in on the whole scheme from the beginning), while Hamilton continued to see Maria for more than a year. This information eventually found its way into the hands of his political enemies, who confronted Hamilton. Hamilton explained that he was not (as had been charged) been playing fast and loose with the nation’s money; but rather he had merely been playing fast and loose with another man’s wife, and paying him off for the privilege, out of his own pocket.”

Today he would be charged with Structuring to evade BSA reporting requirements.

Incidentally, Hamilton was also NYS’s first Chancellor of its Board of Regents and you can find his portrait in the Education Department building in Albany. (


Entry filed under: Compliance, Economy, Mortgage Lending, New York State, Regulatory. Tags: , , .

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Authored By:

Henry Meier, Esq., General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association.

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