When the CFPB assumed RESPA enforcement from HUD in July 2011, it pledged to apply its predecessor’s official commentary, guidance and policy statements until further notice, the brief argues.
Some observers believe the CFPB is questioning whether certain LOS vendors are qualified to serve the industry, fearing a potential crackdown on such companies.
The guidance doesn’t “tells us anything more than where we were an hour before this guidance came out," according to Michael Barone, a director of legal and regulatory compliance at Lenders Compliance Group.