1. Roundtable Executive Summary Bulletin
May 6, 2011
LEGISLATION
Mark-up: CFPB
The House Financial Services Financial Institutions Subcommittee today marked-up three bills to
amend the powers of the Consumer Financial Protection Bureau. All three bills passed on a
party-line vote, and are scheduled for Full Committee consideration next week on Thursday, May
12th. Two amendments to H.R. 1121 submitted by Reps. Maloney (D-NY) and Velazquez (D-NY)
failed. The Roundtable supports the passage of these important bills.
The bills would:
- Replace the bureau’s independent director position with a five-member commission (H.R.
1121 – Bachus).
- Delay the full transfer of powers to the CFPB until a Director is in place (H.R. 1667 –
Capito).
- Allow the FSOC to veto rules written by the CFPB on a simple majority, while using a
review standard that finds that the rule is “inconsistent with the safe and sound
operations of United States financial institutions” (H.R. 1315 – Duffy).
[Scott Talbott, Scott@fsround.org].
REGULATORY
Roundtable Submits Comment on FDIC Brokered Deposits Study
This week the Roundtable filed comments responding to the FDIC’s study on Brokered Deposits
as mandated by Section 1506 of the Dodd-Frank. A link to the final letter is available here. The
Roundtable believes that the Study should address five key issues:
1. The Study should recognize the relationship between brokered deposits and the
FDIC’s DIF assessment system.
2. The Study should recognize that in certain respects, the FDIC has ample
flexibility as to how it can address the issue of brokered deposits.
3. The Study should recognize that brokered deposits may be re-classified based
on the duration of the account relationship.
4. The Study should clarify that deposit funding that is “sticky” should not be treated
as brokered deposits. “Stickiness” of a deposit can be demonstrated by (i) the aggregate
average duration of the account relationship; (ii) the duration of the individual account
relationship; and (iii) the amount of time that the funds have been deposited with the IDI
(e.g., once a deposit has stayed with an IDI for a year, it should no longer be viewed as
brokered).
5. The Study should recognize the stability of brokered deposits that arise from
established referral relationships.
[Brian Tate, Brian@fsround.org or, Brad Ipema, Brad.Ipema@fsround.org.]
2. Roundtable Swaps Groups Remains Active in Multiple Areas Regarding Title VII of Dodd-
Frank
The Roundtable’s Swaps Working group continues to prepare comment letters on the following
topics:
• Rationale and order for rulemakings under Title VII of the Dodd-Frank Act
• Problems with the CFTC’s proposal on required swaps documentation for swap dealers
and major swap participants
• Proposal by Prudential Regulators on margin requirements for swap transactions
• Proposal from the CFTC on margin requirements for swap transactions
• The Proposed Exemption of Forex Swaps and Forwards from CFTC Regulation
The Roundtable is also reviewing a joint SEC/CFTC notice of proposed rulemaking (NPR) on
which swap products will be regulated under Title VII. The Roundtable is also preparing a
summary of a two day roundtable meeting held by the CFTC and SEC on May 2-3 on Title VII
Implementation. The Swaps Working Group also continues to receive updates on H.R. 1573, a
bill pending in Congress that would allow regulators more time to institute the systems required
under Title VII of Dodd-Frank. [Robert Hatch, Robert@fsround.org.]
For More Regulatory Updates, Check this Week’s “Rules in Focus” Memorandum
For the latest updates on the Roundtable’s regulatory efforts, please consult the Roundtable’s
weekly “Rules in Focus” publication. Past editions of the publication are available here.
[Robert Hatch, Robert@fsround.org.]
HOUSING
Housing Policy Council Comments on TILA/RESPA Harmonization
On May 5th, the Housing Policy Council and the Financial Services Roundtable submitted a
comment letter on the Department of Treasury and Consumer Financial Protection Bureau’s
submission to the Office of Management and Budget on the qualitative testing of integrated
mortgage loan disclosure forms. In the comment letter, we state that the model form needs to be
flexible for different products, the Bureau must consider issues posed by mandated redisclosures,
the bureau should engage with compliance experts early in this process, and the Bureau should
reach a broad audience in testing. The final letter can be found here. [Paul Leonard,
Paul@fsround.org]
HOPE LoanPort® Update
HOPE LoanPort® continues to grow, expanding non-profit counselor participation as part of the
ongoing effort to reach homeowners looking to avoid foreclosure. Over 500 counseling agencies
with over 2,300 counselors, in 46 states, the District of Columbia, are using the portal to submit
complete loan modification applications directly to mortgage servicers. On average it takes about
21 days for a counselor to submit a complete application in HOPE LoanPort®, and 26 days to
approve, or 11 days to deny a loss mitigation application. Servicer partners represent more than
80% of the total mortgage market. There are currently more than 800 servicer users serving as a
"single point of contact" that are using HOPE LoanPort®.
Next week HUD is sponsoring a HOPE LoanPort Training session on Tuesday, May 10th for all
counselors across the country. HOPE LoanPort will also be presenting at NeighborWorks®
America's National Training Institute in Detroit, MI on May 17, 2011. [Brad Dwin, (202) 589-1938,
Bdwin@hopeloanportal.org]
3. TECHNOLOGY
2011 FS-ISAC & BITS Annual Summit
At the FS-ISAC & BITS Annual Summit, May 2-4 in Miami, 500 financial services, technology, risk
management and security professionals convened to discuss the highly dynamic cybersecurity
landscape and industry-wide efforts to improve resilience. Stakeholders exchanged information
and strategies for understanding and mitigating cyber threats, securing email, using social media
and meeting the challenges of data security, data sprawl and data breaches, among other topics.
BITS moderated panels on the regulatory environment and securing the internet. [Ann Patterson,
Ann@fsround.org].
Financial Top Level Domains (.bank/.insure/.invest)
ICANN and its Governmental Advisory Committee continue to narrow their disagreement in areas
of trademark protection, objection processes and the treatment of regulated and sensitive strings,
in anticipation of a June 20 vote on gTLD expansion. BITS, ABA and Verisign are refining an
analysis of the financial domain options and will begin to tally institutions' interest in May. [Leigh
Williams, Leigh@fsround.org].
Hearing: ICANN gTLD Oversight
On May 4, the US House Subcommittee on Intellectual Property, Competition and the Internet
hearing on "ICANN generic Top-Level Domains (gTLD) Oversight” focused on the Who-is
database. While there was support for gTLD expansion, delaying ICANN’s June 20 vote on gTLD
expansion was recommended until trademark safeguards are in place. Witnesses: Kurt Pritz,
SVP, Stakeholder Relations ICANN; Mei-lan Stark, SVP, Intellectual Property, Fox Group Legal
Treasurer, International Trademark Association (INTA); Michael Palage, President and CEO
Pharos Global; Steven Metalitz, Counsel Coalition for Online Accountability; Steve DelBianco,
Executive Director NetChoice; and Joshua Bourne, President Coalition Against Domain Name
Abuse (CADNA). [Leigh Williams, Leigh@fsround.org].
Sony Breach Information
On May 4, the FS-ISAC and BITS released additional information regarding the Sony breach,
including an incident overview and recommended next steps for institutions. [Andrew Kennedy,
Andrew@fsround.org].
RESEARCH
Did you know that the CFPB currently has over 200 employees?
An organizational chart of the CFPB is in this week's fast facts, posted here.
[Abby McCloskey, Abby@fsround.org]
INSURANCE
Agents for Change Advocacy Efforts
The sixth annual Agents for Change legislative conference will be held May 10-12 in Washington,
DC. Attendees will hear from high level guest speakers, network with peers, and enjoy private
tours of Washington, D.C. landmarks including the United States Capitol.
Additionally, members of Agents for Change will be meeting with Rep. Hansen Clarke in Detroit,
MI on May 17 and Rep. Peter Roskam in Bloomingdale, IL on June 6. [Peter Ludgin, 202-589-
1929]
4. COMMUNITY SERVICE
Financial Literacy Month Overview
While National Financial Literacy Month has officially ended, the effort to strengthen America's
financial literacy continues. Click here for a review of the financial services industry’s impact in
communities and a look ahead. [Aleksia Ilic, Aleksia@fsround.org]
Community Service in the News
• San Francisco Mayor Edwin Lee and Oakland Mayor Jean Quan Kick Off Forum on
Earthquake Risk, May 2, 2011
• Citi-Funded Study Finds If One in Three Microenterprises Hired One Employee, U.S.
Economy Would Reach Full Employment, May 2, 2011
Roundtable Awards University of Scranton Student with Foundation Scholarship
The Financial Services Roundtable announced that Robert Della Polla of the University of
Scranton is the recipient of the 2011 Roundtable Financial Scholarship in honor of Christopher M.
Condron, Retired Chairman, AXA Equitable. Della Polla will be entering his junior year as an
accounting major at the University of Scranton in the fall of 2011. Read more.
Community Service 2011 Company of the Week: Citi
Week of May 1, 2011
Citi Celebrates Small Business Month
From left, Bob Annibale, Citi’s Global Head of Microfinance and Community Development; Rob
Walsh, Commissioner NYC Department of Small Business Solutions; Vikram Pandit, CEO Citi;
and Gina Harman, CEO ACCION USA.
Citi’s commitment to Responsible Finance reflects our understanding of the central role of
financial products and services in expanding financial inclusion and community development.
With particular emphasis on underserved families and communities, we have a continuing, core
focus on neighborhood revitalization, financial capability and asset building, college completion
and, importantly, small business development. Small businesses are key engines of any local
economy and are critical to creating jobs. Read more. [Aleksia Ilic, Aleksia@fsround.org].
5. The mission of The Financial Services Roundtable is to protect and promote the economic vitality
and integrity of its members and the United States financial system.
www.fsround.org