Thursday, January 26, 2012

CFPB's Cordray: "If you stay away from pretty outrageous practices, you should be safe."


Only 48 Examinations Planned for this Year


"I don't think there is a lot of uncertainty here. I think it's very clear in the statute for something to be an abusive practice it would have to be a pretty outrageous practice," Cordray said. "If you stay away from pretty outrageous practices, you should be safe." 

This was Cordray's testimony on Capital Hill as he worked to justify the build up of the regulatory agency's staff from 800 to an expected 1500 employees.  The $500 Million dollar budget was written into law as part of Dodd-Frank.  

Friday, November 18, 2011

A Simplified Explanation - And Novel Solution - to Preventing the Recurrence of the Credit Crisis


With all of the "Fixes" for the Credit Crisis still underway, most people still don't understood how the market failed to create safeguards for itself.  Fed Chairman Bernanke attributed the crisis to a market failure, but how can a market fail, unless there are undue influences?  The influence, ironically, was a flight to safety itself.  The mechanics of how unsafe investments were transformed into "safe investments" is now well understood, but it was the demand for safety, itself, that created the crisis.  The solution, it turns out, is the government guaranteeing as much cash as it can (by borrowing) regardless of whether it is willing to. 

Zoltan Pozsar, a visiting scholar at the IMF, shows that the shadow system was fueled by institutional investors looking for a safe place to park large amounts of cash. There weren't enough short-term Treasuries to fill demand, nor were there enough banks to store the money in amounts below the FDIC insurance limit. So the investors found their cash-storage facilities at one end of the shadow banking system's "risk-stripping" assembly line.

At the other end was the by now well-known process in which pools of questionable loans were repackaged into triple-A securities (what Pozsar calls "credit transformation"). Said securities were then placed into investment vehicles funded with short-term instruments like repos and asset-backed commercial paper ("maturity transformation"). And those instruments were then placed in money market funds one could write checks against ("liquidity transformation").

The resulting "privately guaranteed instruments" ended up being the government's problem when the crisis hit, Pozsar writes; the shadow banking system's short-term obligations "were guaranteed by insured banks and hence ultimately the sovereign (whether via central bank backstops or equity injections)." So why not just accommodate the demand for a safe haven by having the government write more of its own IOUs? Pozsar acknowledges the obvious objection - that this "would increase rollover risks and the variability of interest expenses for the US Treasury." But he submits that the "externality," or cost to society, would be less than risking another crisis.

Sourced by American Banker Newsletter

Tuesday, November 8, 2011

CFPB reveals larger prototype mortgage form for public scrutiny « HousingWire

CFPB reveals larger prototype mortgage form for public scrutiny « HousingWire

This is another form in sheep's clothing. The agency has attempted to consolidate 2 or 3 forms, but has done nothing to address the remaining 25. Again, the practice is still one of burying the details in reams of paper.

Monday, November 7, 2011

Renewal Season STARTS in Maryland 11/1/11

Renewal applications for mortgage lenders and mortgage loan originators are accepted beginning November 1, 2011.  The deadline is December 31, 2011. 

We get many questions about what needs to be taken when.  "I took the 20 hours last year - do I have to take it again?"  Maryland has put together a matrix explaining the requirements:

chart  
What Do I have to Take?
  • 3 hours of federal law and regulations;
  • 2 hours of ethics that shall include instruction on fraud, consumer protection, and fair lending issues;
  • 2 hours of training related to lending standards for the nontraditional mortgage product market; and
  • 1 hour of instruction on Maryland mortgage-related laws.
A "covered employee" means the manager of each corporate office and branch office licensed, or required to be licensed, by the Agency.  A covered employee does not include a manager of the licensee who has been an employee for less than six months before the expiration of date of the licensee's current license and has had no prior experience as a manager of any other licensee.  

I Did Not Know That

You MUST Resolve any outstanding personal income tax, business tax and/or unemployment insurance liabilities with the State of Maryland, BEFORE a renewal application can be accepted. Contact the following, if applicable:
  
Income Tax: 410-974-2432
Business Tax: 410-649-0633
Unemployment Insurance Tax: 410-767-2699

In addition, companies must:

Confirm that licensee is in good standing 
Continue to satisfy the minimum net worth requirements

Friday, November 4, 2011

If I gave you a FREE Tree, and it saved you money...

...Would you plant it? 

That's what Pepco is doing.  It's not rocket science - everyone knows it's cooler in the shade, yet we let our houses (with their black, heat absorbing roofs) sit complete exposed while we throw money at our utilities to cool our homes.  The best antidote to sun is shad, and the best way to get shade in the summer (and not in the winter when you want the sun to warm your home) is to strategically plant trees.

Utility companies across the country are becoming partners with the Arbor Day Foundation to help reduce energy use through strategic tree planting..

Energy-Saving Trees is a research-based tool intended to help homeowners and utility companies save energy and money by strategically planting trees. This really cool (no pun intended) tool sees how much shading your house will do to reduce your energy costs.  AND a tree sequesters carbon! Learn More.