cfpb agency servicestoolkit-fordistribution

Agency Services CFPB Toolkit

How am I going to learn CFPB?…..”CFPB 101”

Introducing…..

Agency Services CFPB ToolkitThe complete resource that contains everything needed to establish you and Stewart as the CFPB “go to” resource with our independent agencies.

The Toolkit includes everything needed for you to provide both group and one-on-one presentations on the topic of CFPB requirements for service providers. When giving those presentations, you will also be able to share exciting news about the Stewart Trusted Provider CFPB Toolkit for our independent agencies to use in marketing to both Lenders and REALTORS® in their local markets.

Agency Services CFPB Toolkit

• Marketing Plan• CFPB 101 Quick Start• Handouts• Flyers• Emails• Invitations• Presentations• Checklists

Stewart Trusted Provider CFPB Toolkit

• Marketing Plan• CFPB 101 Quick Start• Handouts• Flyers• Emails• Invitations• Presentations• Checklists

Available Today

Coming Soon!!

*Available on Stewartmarketing.com

Agency Services AssociatesYou recently received an email with the announcement shown at the right providing highlights of this marketing program.

This effort is patterned after the successful “CFPB Seminar-in-a-Box” program used by direct operations. With Stewart associates having presented at more than 500 events – the success continues. Just like the effort in direct operations, your events and success stories will soon be tracked in CRM with reports going to the District Managers and George Houghton. The idea is to present to agencies “one-on-one” in their offices during quarterly visits.

As you view this presentation, note that the slides shown as “Backstage” contain information for you about the program and presentations that you will give to the Stewart agencies. Portions of the presentation (slides 9 – 34) featuring Stewart’s lighthouse theme contain the “script” that you will use when presenting to your agencies. We’ve included speaker notes allowing flexibility in length of presentation since both ‘basic’ and ‘extended’ information is included. Longer presentation? No problem, just include the extended information following the basic.

Finally, toward the end of the presentation (slides 35-52) will be a review of the “private label” CFPB presentation that will be available to Stewart agencies for providing CFPB updates and marketing their Trusted Provider status to REALTORS® and Lenders in their local markets. These Powerpoint slides are easy to spot as they are “private label” and include the Trusted Provider logo at the bottom.

Next Steps and Additional Information1. Watch Video

a) View this complete video and take notes. Write down any questions or concerns you may haveb) NOTE: If you have not watched the video, do so today!!

2. Review Recorded Discussion WebEx Conference Calla) On February 25th or 26th, Marvin Stone and George Houghton hosted a Discussion WebEx Conference Call. Watch the recorded

version as a reminder of the information you need to remember when presenting to your agenciesb) Direct any questions you may have to your District Manager

3. Continue the Train-the-Trainer dialoguea) The video and the recorded WebEx session will constitute most of the trainingb) Your District Manager and Executive Management are fully aware of your time constraintsc) Continue to provide suggested improvements for the Toolkit and FAQ’s, CFPB Questions, See Escalation Path (below), etc

4. Escalation Path for Questions or Suggestions for Improvementa) ASM/ASR > DM > Gloria Prinz > George Houghton/Pat Beall cc: Marvin Stone

5. Promote the Stewart Trusted Provider Presentationa) The Trusted Provider CFPB Toolkit Presentation was created for your independent agencies to present to their REALTOR® and

Lender customers. It’s a locked-down PDF presentation with a place for your independent agencies to add their company logob) Have your agent present on their own or you can partner with your agent to present to their customers

6. TIPS/Agency Conference Mentionsa) News, current events, high-level info > call to action (workshop)

http://www.screencast.com/t/0DfyZ89Xe0

The “Real World” Timeline for Lenders

About the PowerPoint The following PowerPoint presentation has been designed to make it easy for you, the Stewart Agency Services associate, to give a CFPB update of varying lengths depending upon the audience and time allotted.

The speaker notes are provided in “Basic” and “Expanded” sections. Cover the Basic section in your own words in each presentation – then continue talking through the Expanded section if time is available or if the subject matter is of greater interest to your current audience. Practice to understand the impact that adding the Expanded notes will have upon the length of the presentation.

9

CFPB Updatefor

[Insert ASM/ASR Name]

- About the CFPB

- Effective Date

- Loan Estimate

- Closing Disclosure

- Delivery Alternatives

- Three-Day Rule

- All-In APR

- Electronic Storage

- Proposals Not Adopted

Today’s Topics

- History of the CFPB

- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation

- Trusted Provider Toolkit

- Next Steps

- Q & A

10© Copyright Stewart 2014

History of the CFPB

CFPB formed with Richard Cordray as Director Supervisory authority over Banks and Non-Banks. Enforcement authority over RESPA and TILA

-

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


DisclosuresMeet CFPB and lender requirements:1.Produce for or by settlement2.Lender delivery – or –3.Settlement delivery4.Unroll Title Services Fees5.Prepare for 3-Day Rule6.Understand Tolerances7.Prepare for Trial Period

ControlsMeet requirements of the following:1.ALTA Best Practices2.CFPB Service Provider Bulletin3.OCC Bulletin on Third-Parties4.FDIC Bulletin on Third Parties5.Fourth-party risk

ComplaintsImprove Documented Process for:1.Consumer complaints2.State regulator complaints3.CFPB complaints database4.Lender requirements

TransformationChange the closing process to:1.Reduce number of disclosures2.Ensure accurate quotes3.Deliver docs earlier 4.Educate consumers

2 3 41

Areas of Focus

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


CFPB Finalizes Rule on Integrated Disclosures

Better Disclosures

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Closing Disclosure for Purchase

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Service Provider “flight to quality”

CFPB Bulletin to Banks and Non-Banks stating they must use quality service providers.

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A



Other regulators restating their requirements for “third-party risk”

Federal ReserveFDICOCCFFIEC

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A



1. Current Licenses - Establish and maintain current License(s) as required to conduct the business of title insurance and settlement services.

2. Escrow Accounts - Adopt and maintain appropriate written procedures and controls for Escrow Trust Accounts allowing for electronic verification of reconciliation.

3. Privacy Program- Adopt and maintain a written privacy and information security program to protect Non-public Personal Information as required by local, state and federal law.

4. Settlement Procedures- Adopt standard real estate settlement procedures and policies that help ensure compliance with Federal and State Consumer Financial Laws as applicable to the Settlement process.

5. Title Procedures - Adopt and maintain written procedures related to title policy production, delivery, reporting and premium remittance.

6. Insurance Coverage - Maintain appropriate professional liability insurance and fidelity coverage.

7. Complaints Process - Adopt and maintain written procedures for resolving consumer complaints.

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Stewart Trusted Provider Policy TemplatesSample

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Stewart Trusted Provider Policy TemplatesPolicies and procedures for your agency to customize and deploy for a compliance quick start

1.Account Management Policy

2.Acknowledge Receipt of Policies

3.Anti-Fraud – Corruption Policy

4.Anti-Virus Malware Policy

5.Application Security Policy

6.Background Investigations Policy

7.Backup and Media Retention Policy

8.Business Continuity Plan Template

9.Business Continuity Policy

10.Business Continuity Prep/Response Plan

11.Customer Complaint Tracking Form

12.Customer Complaint Policy

13.Data Retention Policy

14.External Audits Policy

15.Fair Lending Compliance Policy

16.Foreign Corrupt Practices Act Offshore Tasks Policy

17. Instant Messaging Policy

18. IT Security and Computer Usage Policy

19. Managing Exceptions Policy

20. Managing Exceptions Process

21. Mobile Devices Policy

22. Non-Public Information Security & Disposal Policy

23. Notary Services Policy

24. Password Policy

25. Policy Exception Request Form

26. Privacy & Information Security Audit/Oversight Policy

27 Remote Access Policy

28 Security Incident Response Policy

29. Security Training and Awareness Policy

30. Social Media Policy

31. Standards of Conduct Policy

32. Title Insurance and Settlement Services Policy

(Bold indicates new releases in October 2013)

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Stewart’s Approach to Due Diligence & Monitoring

Initial Due DiligenceIndependent pre-sign audit by Deloitte

Thorough background and credit checks

Examination of applicant’s business model

Review of applicant’s policy loss history

Verification of licensing

On-going Monitoring•Regular Deloitte audits based on risk

•Quarterly on-site visits

•Quarterly operational checks

•Policy inventory audits

•Comprehensive operational review

•Title/settlement loss prevention training

•Regulatory compliance training

•Random background and credit checks

•License verification

•Review of E&O / fidelity bonds

•Agency validation web service*

In the United States, Deloitte LLP and its subsidiaries have more than 57,000 professionals dedicated to providing audit, consulting, financial advisory, risk management and tax services to selected clients. With over 100 years of history and a global network of highly-trained professionals, Deloitte is a trusted partner to the top names in financial services

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Stewart Trusted Provider Program

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Memorialized Due Diligence Response

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Complaints

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Stewart Trusted Provider Policy Templates

Sample

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Transforming the Closing Process

“So as part of our “Know Before You Owe” initiative, we are making a commitment to work with industry to improve the mortgage closing experience for consumers through technology. We believe that “eClosings” could represent a positive development along these lines, and we want to know more about how we can foster innovation in this area.

CFPB Director Richard CordrayBoston Field Hearing,November 20, 2013

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Transforming the Closing Process

Five major goals in this new initiative:

1.Create efficiency with technology

2.Reduce the number of disclosures

3.Ensure the accuracy of up-front quotes

4.Deliver docs earlier in the process

5.Educate the consumer

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Resources

stewart.com/cfpbService Provider Memo

ALTA Best Practices

QM / ATR

Integrated Disclosures

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Stewart Trusted Provider Seal

Show Lenders, REALTORS®, Consumers and Business Partners YOU are the agency they need to work with

You’ve been vetted and verified by: Passing an intensive due-diligence screening Conducting business according to our stringent Independent Agency

Standards Undergoing strict ongoing monitoring

You’re a trusted provider of real estate settlement services Add the seal to your website, email signature and marketing collateral Visit stewart.com/agencytrust

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Stewart Trusted Provider Seal with ESB

With a Stewart Escrow Security Bond (ESB), you’re a Trusted Provider with even more security

An ESB, underwritten by Lloyd’s of London®, may provide settlement fund recovery as a result of fraudulent activities, including:

Computer crime rider Cyber liability – Consumer data security Employee theft coverage Partner/principal theft coverage Embezzlement Payable fraud Receivable fraud Diversion schemes Fictitious write-offs Expense schemes

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Marketing at its Best

Samples Emails

Flyers

Drop Cards

eCards

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Next Steps

Follow CFPB news and updates on Stewart.com/cfpb

Leverage the Stewart Trusted Provider Policy Templates

Regularly attend the Stewart Agency Services webinars

Refine your consumer complaints process Implement the Stewart Trusted Provider CFPB

Toolkit Ensure your buyers and lenders are protected by

Stewart

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Q&A

- About the CFPB

- Effective Date

- Loan Estimate



- Three-Day Rule

- All-In APR



Today’s Topics


- Areas of Focus

- Disclosures

- Controls

- Complaints

- Transformation


- Next Steps

- Q & A


Thank You

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