Thu Mar 28 19:13:13 EDT 2024
HomeBlogLicensing: It's Not Just For The Contractors

Licensing: It’s Not Just For The Contractors

2014 is going to be a buffet for regulators. The Consumer Financial Protection Bureau (CFPB) has a mountain to climb and a limited amount of pitons in its proverbial inventory. Part of the reason for a lack of the regulatory pitons is that Congressional Members on both sides of the Aisle are nervous with respect to that which the CFPB hopes to accomplish.

The CFPB is sharpening their pencils with respect to the Mortgage Field Services Industry (Industry). As early as January, 2013, the Industry knew it was coming down the pike. Regulation X (See Below), as many like to call it, is 72 pages of a humdinger breakdown by the Federal Reserve. Here's the catch: How many Contractors even have an idea that this Regulation exists let alone what it means?!

The Legacy of Dodd - Frank, the 800+ Page monstrosity issued in a knee jerk reaction by Congress, is going to probably do everything except that which it was originally intended to do. It will take more man hours EVERY YEAR to comply with the first third of the Regulations --- 4.18 MILLION MORE MAN HOURS THAN IT TOOK TO BUILD THE PANAMA CANAL!

Dodd-Frank, passed by Congress in 2010, mandates that government regulators write over 400 new rules and requirements that will be imposed on the private sector. Since the law was signed by President Obama in July 2010, the Dodd-Frank Burden Tracker reveals:  1) regulators have written 224 of the 400 rules; 2) these 224 rules consume 7,365 pages; and 3) it will take private sector job-creators 24,180,856 hours every year to comply with these first 224 Dodd-Frank rules.

CFPB is looking to create a niche for itself. Make no mistake that the Mortgage Field Services Industry is creating a fertile environment. Whether or not the National Association of Mortgage Field Services intends to be the Poster Child for CFPB, the issues which are currently out there are going to become the Holy Grail very soon without being addressed.

While this Article is about CFPB and the complexity of Regulation, the reality is that NAMFS will become CFPBs Scope. The defense to any Contractor being nailed for lack of Regulatory Oversight will be the Origination of the Order. In this, NAMFS has a prime opportunity to alleviate itself of the bad publicity and implement Compliance for its Client.

Here is the rub: Contractor A goes out to perform an Occupancy Inspection for an NAMFS Member whom gets that Order from another NAMFS Member which Originates from a Financial Institution. The Financial Institution Originates the Work Order on Day 12 of the Early Intervention Requirement under 12 CFR 1024.39; the National Order Mill rolls out the Work Order on Day 16; the Regional Order Mill rolls out the Work Order on Day 31; and the Contractor receives it on Day 35.

Seemingly, this is a normal timeline; however, let's go ahead and NOT CONSIDER IT ALREADY VIOLATES 12 CFR 1024.39 --- IF YOU DO NOT UNDERSTAND THE CODE OF FEDERAL REGULATIONS ...

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Paul Williams
Paul Williamshttps://foreclosurepedia.org
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