October 28, 2021

Reg F Priorities

Carl Harkleroad

We are less than three months away from the new CFPB Rule and Reg F taking effect in the Financial Services Industry. For the next three weeks I will be providing some valuable information to my industry colleagues that may help you bridge the gap with the short window that is available.

The subject for this week is “What are the TOP PRIORITY Items?”. Here is a list that provides a valuable prioritization roadmap and should begin immediately.

1. Letter Validation Modeling

Model validation letter should be your top priority at this point; Most importantly, ensuring that creditors can provide the balance and validation dates to agency partners.

2. Interpret Rules

Creditors should communicate the Rule’s internal legal interpretation to agency partners. Creditors should allow their legal / compliance teams to interpret the rules and disseminate expectations accordingly to the agencies.

3. Agency Collaboration

Strategic collaboration with the agencies and their clients. The client should lead the charge since each may have different challenges and expected rules of engagement

4. Data Continuity

Creditors need a synchronized interface with their loan servicing system/ collections platforms. This is important for timely data communication and continuity with the agencies / servicers.

5. Data Exchange

Both the creditors and servicers need to ensure that have established cohesive communication / data exchange and are spot on with execution on Day 1.

6. Small Scale Testing

Start testing now on a smaller scale so you are ready on November 30th.

About Us

Imagined.Cloud, founded in 2017, builds event-driven solutions with security, compliance, scalability and developer friendly API's for complete receivable cycle management. Standard KPIs and modern data schemas provide a unified view of work efforts across agency and vendor networks. For more information about our products, contact sales@imagined.cloud or by dialing +1 866 787 0730‬.

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