The Problem: In October 2015 the CFPB issued an executive summary spelling out new reporting requirements. Beginning in January of 2018, lenders will be required to report much more detail per transaction including: points and fees, borrower-paid origination charges, discount points, lender credits, and loan originator identifier.
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A common problem in any organization is getting the compliance department and the sales department to share common goals and work synergistically. The sales organization in any mortgage company is typically in a consistent state of change especially as the consumer evolves and Millennials grow to the age and circumstance to buy a home. While the consumer evolves, so do the means by which consumers become educated on the numerous choices they have to qualify for and secure mortgage funding. New technologies that lenders employ to take advantage of these consumer trends can create new marketing risks. New marketing tools create risks to lenders, and, to make matters increasingly difficult, the Consumer Financial Protection Bureau (CFPB) is heavily involved in overseeing and auditing lenders on marketing processes, systems, and the resulting messaging. Additionally, with heavy oversight from the CFPB on credit reporting agencies, mailing offers of credit to consumers on prescreened lists is a hot topic of discussion among mortgage lenders.