September 14, 2021

Reg F Planning

Carl Harkleroad

Last week I outlined top priorities for agencies and creditors to execute for their roadmap to meet the CFPB Rule and Reg F requisites by November 30th. In today’s article I want to zero in on other opportunities that should be part of your planning and discussion in preparation for the new changes.

1. Compliance Policies

Make sure that your policies and procedures are aligned with your organizations interpretation and directives for the new Rule.

2. Risk Determination

If there are any perceived gaps, your organization should explore and determine your risk tolerance. Make the easy changes that can be made immediately and develop an action plan to address the larger gaps.

3. Task Management

Execute with a “preferred” or “required” mentality. It should go without saying that REQUIRED takes precedence over anything else on the task list.

4. Constant Communication

Creditors should facilitate consistent communication with your agencies /servicers to drive their planning and ensure proper alignment.

5. Change Management

Establish and maintain a “change management” cadence and prioritization plan. You should expect that many states will be adapting their own version of consumer protection laws (i.e. California Department of Financial Protection and Innovation – DFPI). With this is place you will be able to proactively respond to these changes.

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