1. MISMO January 2012 Trimester Meeting One Ocean Resort, Atlantic Beach, FL January 23, 2012 The Legislative and Regulatory Landscape - - presented by – Jack Konyk Executive Director, Government Affairs Weiner, Brodsky, Sidman, Kider PC - - for - -

2. MISMO January 2012 Trimester Meeting One Ocean Resort, Atlantic Beach, FL January 23, 2012 The Regulatory and Legislative Landscape What has happened or is happening now? How is the landscape changing ? What will the new landscape hold ?

3. MISMO January 2012 Trimester Meeting One Ocean Resort, Atlantic Beach, FL January 23, 2012 What has already happened or is happening now? –LOTS of controversy with LOTS of existing regulations TILA – L O Compensation and Appraisal Independence RESPA – still trying to clarify GFE/HUD-1 questions SEC – regulations overturned on procedural technicality –New bureaucracies created CFPB fully operational (but controversially) Existing regulators coping with new responsibility alignment –And there’s another election coming up! The Regulatory and Legislative Landscape

4. MISMO January 2012 Trimester Meeting One Ocean Resort, Atlantic Beach, FL January 23, 2012 How is the landscape changing ? –Bureau of Consumer Financial Protection (CFPB) up and running Became real on July 21, 2011 Major functional areas have been busy Cordray given recess appointment as Director; Republicans furious! The Regulatory and Legislative Landscape

5. MISMO January 2012 Trimester Meeting One Ocean Resort, Atlantic Beach, FL January 23, 2012

6. MISMO January 2012 Trimester Meeting One Ocean Resort, Atlantic Beach, FL January 23, 2012 How is the landscape changing ? –Bureau of Consumer Financial Protection (CFPB) up and running Became real on July 21, 2011 Major functional areas have been busy Cordray given recess appointment as Director; Republicans furious! –Other existing regulators coping with transition of authorities Existing reg’s re-published without changes; new rules in development (QM, QRM, etc) Some affected staff transferred, but often NOT to similar positions Still other things require JOINT working with CFPB, so coordination needs managed –Lots of posturing for the 2012 election impacting operations House has passed many bills that would change the Bureau Bureau anxious to put so much in place that modifications will be difficult to achieve Political backlash from recess appointment needs to play out The Regulatory and Legislative Landscape

7. MISMO January 2012 Trimester Meeting One Ocean Resort, Atlantic Beach, FL January 23, 2012 How is the landscape changing ? –Bureau of Consumer Financial Protection (CFPB) will need data to: Collect, research, monitor, and publish information about the functioning of consumer financial products, services and markets to identify risks Collect, investigate and respond to consumer complaints Supervise and examine their institutions for compliance –Other existing regulators will ALSO need data to: Supervise and examine their institutions for compliance (Multi-State or individual) Facilitate the new Multi-State Mortgage Committee “e-Exam” Collect, investigate and respond to consumer complaints –Lenders will need to move data internally to: Interact with various complimentary/support utilities (compliance systems, doc prep, etc) Interact with investor systems for loan delivery and other purposes The Regulatory and Legislative Landscape

8. MISMO January 2012 Trimester Meeting One Ocean Resort, Atlantic Beach, FL January 23, 2012 The Regulatory and Legislative Landscape What will the new landscape hold ? –Change !! (Chaos?) –Some very safe predictions : The R’s, particularly House R’s, will continue to meddle The market structure WILL change (but how, and WHEN) Regulators WILL get tougher, regardless of who that is Existing agencies WILL continue to be very risk-averse Pressure to improve process WILL NOT abate Data, and its movement, WILL REMAIN VITAL

9. MISMO January 2012 Trimester Meeting One Ocean Resort, Atlantic Beach, FL January 23, 2012 The Regulatory and Legislative Landscape Is Your Uniform Dirty?

10. MISMO January 2012 Trimester Meeting One Ocean Resort, Atlantic Beach, FL January 23, 2012 The Regulatory and Legislative Landscape QUESTIONS