In a previous Risk Management Knowledge Exchange post (CFPB interview: Product development and regulatory unrest), I noted that the CFPB (Consumer Financial Protection Bureau) has three markets that it will focus on initially:
- Mortgage brokering and servicing
- Payday lending
- Private student lending
During that BAI Retail Delivery conference session, I also heard David Silberman, the Assistant Director, Deposit and Payment Markets Consumer Financial at the CFPB, discuss an upcoming form that consumers would be able to access to complain about their mortgages. According to The New York Times, that form is now available on the CFPB website. Read the Times’ article to learn what consumers will see:
The Consumer Financial Protection Bureau is offering borrowers an online form to collect mortgage complaints, including problems with the application process or difficulties with making payments. Along with the complaint, the CFPB asks what the borrowers want as a solution. The agency forwards complaints to the lender and allows borrowers to track the progress of the complaint filing. The New York Times/Bucks blog
How do you see that affecting your strategy in 2012 for lending and restructuring of consumer mortgages?
No light at the end of the tunnel?
Now, take a look at this article at TheStreet.com. According to Shanthi Bharatwaj, a financial analyst at The Street, lenders are taking another look at what Bharatwaj labeled the ‘amend and extend’ plan of the past. This plan was based on expectations of a brighter economic future that hasn’t yet materialized. She says that although larger institutions seem to be flush because of the recent emphasis on liquidity, middle market borrowers may be headed for trouble.
Does this affect 2012 strategy? Take a look at this white paper about enlarging the traditional credit risk management repertoire on the one hand, and being more creative in the modeling and management of innovative credit products on the other hand.