Given the ever-increasing regulations pertaining to consumer financial services, servicers and lenders subject to such regulations may wish to voice their opinions and concerns both as to the regulations and the related information collection requirements. The CFPB has invited comment from the public on several topics, including an invitation for public comment by June 8, 2015, regarding an information collection titled, “Registration of Mortgage Loan Originators (Regulation G) 12 CFR 1007.”
Regulation G implements the Secure and Fair Enforcement for Mortgage Licensing Act’s (S.A.F.E. Act) federal registration requirement with respect to any covered financial institutions, and their employees who act as residential mortgage loan originators (MLOs). It would require those covered to maintain a registration with the Nationwide Mortgage Licensing System and Registry and to obtain a unique identifier. The rule also requires the covered financial institutions employing these MLOs to adopt and follow written policies and procedures to ensure their employees comply with these requirements, and to disclose the unique identifiers of their MLOs.
The CFPB has invited comments by June 8, 2015, regarding: (a) whether the collection of information is necessary for the proper performance of the functions of the CFPB, including whether the information will have practical utility; (b) the accuracy of the CFPB’s estimate of the burden of the collection of information, including the validity of the methods and the assumptions used; (c) ways to enhance the quality, utility, and clarity of the information to be collected; and (d) ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques or other forms of information technology. Comments submitted in response to the CFPB’s notice will be summarized and/or included in the request for Office of Management and Budget (OMB) approval. All comments will become a matter of public record.
This invitation for comment is one of several invitations currently pending, and is available at the CFPB’s website (http://www.consumerfinance.gov/notice-and-comment/). As the CFPB notes with regard to this invitation, one of the topics on which it has invited comment is “[w]ays to minimize the burden of the collection of information on respondents.” Because financial institutions have experienced a significant financial burden in the wake of substantially increased regulation, such entities should consider weighing-in when invited to play a role in shaping additional requirements to be imposed upon them.