Pub. 10 2020-2021 Issue 2

O V E R A C E N T U R Y : B U I L D I N G B E T T E R B A N K S — H E L P I N G C O L O R A D A N S R E A L I Z E D R E A M S September • October 2020 7 Chris W. Bell serves as associate general counsel for Compli- ance Alliance. He holds a bachelor’s degree in Political Science from the University of Memphis, a master’s degree in Political Management from the George Washington University, and a law degree from the St. Mary’s University School of Law. Chris began his career working for a regional bank in Tennessee, where he developed a passion for serving customers through the banking system. In law school, Chris focused his studies on the different financial aspects of the law, including the Internal Revenue Code and UniformCommercial Code. Chris has worked in the legal department of a federal savings bank and for the Texas Department of Banking. As one of our hotline advisors, Chris helps C/A members with a wide range of regulatory and compliance questions. The CFPB also discussed its par ticipation in the interagency rulemaking processes to update the guidelines issued by the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA). This partnership with the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Federal Housing Finance Agency is developing regulations to implement the amendments made by the Dodd-Frank Act to the FIRREA guidelines concerning appraisals. The changes require implementing regulations for quality control standards for automated valuation models (AVMs). One of the items listed in the preamble to the CFPB’s Spring Agenda that has not generated much attention is the agency’s study of the impact of artificial intelligence (AI) in the context of federal consumer financial laws and regulations. Banks raised issues related to AI in response to the CFPB’s 2017 Request for Information Regarding Use of Alternative Data and Modeling Techniques in the Credit Process, the Bureau’s 2018 Calls for Evidence, and in other outreach since then. The bureau continues to monitor developments concerning AI and is evaluating whether rulemaking, a policy statement or other action may be appropriate. With the OCC’s recent proposal regarding technological innovation, it would not be surprising to see the CFPB announce something on this topic soon. To fulfill its obligation under Section 1022(d) of the Dodd-Frank Act, the CFPB is also conducting its five-year review of its Integrated Mortgage Disclosures Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z) Rule and certain amendments. The CFPB announced it plans to issue its TRID Rule assessment report by October. The CFPB also expects to conduct an additional review under section 610 of the Regulatory Flexibility Act, which requires the bureau to consider the effect on small entities of the rules it promulgates. The agency plans to review the Regulation Z rules that implement the Credit Card Accountability Responsibility and Disclosure Act of 2009. Stay tuned to Compliance Alliance for announcements on these developments and more. n