June 11, 2025 • 41 mins
The compliance landscape for credit union mortgage operations has never been more complex or critical to navigate successfully. In this eye-opening first episode of our Compliance Summer Mini Series, regulatory expert Michael Christians is joined by ACUMA President Peter Benjamin, warning against developing a false sense of security in today's shifting environment.
While federal regulators may be stepping back from aggressive enforcement, Michael reveals why this doesn't mean credit unions can relax their compliance vigilance. Instead, he explains how State Regulators and Attorney Generals are poised to fill the enforcement void, maintaining pressure on credit unions to uphold strict standards in fair lending, UDAP compliance, and mortgage servicing.
Through practical examples and clear explanations, Michael guides listeners through the most pressing compliance challenges facing credit unions today. He explains how fair lending enforcement is evolving under the current administration, why UDAP can touch virtually every corner of mortgage operations, and how seemingly simple oversights like failing to terminate PMI on time can create significant consumer harm and regulatory risk.
Tune in now as Michael uses his expertise to translate complex regulatory concepts into actionable insights, making this episode particularly valuable.
Sponsored by Consolidated Analytics
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Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:00):
The views and opinions expressed in this
podcast do not necessarilyreflect the views or positions
of Acuma, its board of directors, its management staff or its
members.
The podcast discussionpresented is conversational in
nature and for generalinformation only.
Speaker 3 (00:32):
Hello and welcome to Active Zone Point Podcast, a
series focused on sharing thestories of people who are making
a positive impact in the creditunion mortgage industry.
I'm your host, Peter Benjamin.
Before we get to our episode,just a quick word from our
sponsor.
Speaker 4 (00:42):
This episode is brought to you by Consolidated
Analytics, helping credit unionsmake smarter mortgage decisions
, from origination to servicingand beyond.
With expert valuation, riskmanagement and compliance
solutions, they provide theinsights you need to protect
your members and grow yourportfolio with confidence.
Whether it's due diligence orcollateral risk assessment, they
(01:03):
help you navigate the marketwith ease.
Learn more atConsolidatedAnalyticscom.
Speaker 3 (01:08):
Welcome to the first episode of our Compliance Summer
Miniseries, where each episodewill feature an intimate
conversation with people who Iconsider to be experts in their
field and supporters of thecredit union movement.
It's our goal with theseepisodes to take a deep dive
into various compliance topicsthat are impacting and reshaping
the credit union mortgageindustry.
(01:29):
Our first guest in thecompliance miniseries is our
friend, michael Christians.
Regulatory Compliance Counselwith Michael Christians
Consulting LLC.
Michael, my friend, how are youdoing today?
Peter?
Speaker 5 (01:43):
I'm doing well.
It's great to be with you.
Thank you for the invitationand, yeah, I imagine we've got
some things to talk about, don'twe?
Speaker 3 (01:54):
I mean one.
It's never boring with you.
It's compliance.
Compliance is a broad topictopic and it overlaps with a lot
of different things.
You could easily say compliance, you could say policy, you
could say regulations, all ofthe above.
They're like triplets runningdown the street holding hands.
(02:17):
So it really is this massivetopic.
It's one of my favorite thingsto discuss because it's this
weird anomaly of a thing that noone ever seems to get right.
You know, as funny as it sounds, you and I could read something
you know 10 times and interpretit completely differently.
(02:40):
Yep, and that's all it is.
Speaker 5 (02:43):
It's all up for interpretation and, and to that
point um, both of ourinterpretations, although
completely different, areprobably accurate to some extent
right, that's exactly it.
Speaker 3 (02:54):
That's exactly.
And the funny thing is is thatwhen they write these rules,
they purposely leave, like thesegray areas, sure, and so that's
why we're doing this.
You know, the summer miniseriesspecifically focus on
compliance with the hopes thatwe shed some light on the gray
areas.
(03:14):
Now, before we get to the meatand potatoes, like we always do,
got to bring Justin in.
Justin the hawk, the screechsound just went off.
I'm not gonna do it again.
But, justin, how are you doingtoday?
And please tell us what is thelatest and greatest happening
over at acuma?
Speaker 2 (03:35):
I'm good, peter.
How are you living?
The dream man, that's good.
I'm glad that you also didn'ttry to make that hawk sound
again that was did it once andI'm never, ever, ever going to
do it again.
Yeah, I mean, you just got to gowith the caca.
That's the call of the day atthat point.
You're not cool enough.
That's what it is.
You don't have the namesake tobe able to do it, that's okay.
(04:00):
Anyways, we just got back fromSeattle last week.
That was super exciting.
It was great to see all of ourmembers engaging and interacting
with each other.
That rounded out our focalpoint workshops.
So if you missed them, youmissed some great events.
That's all I'm going to say.
They were good, they werefantastic.
So up next, for in-person, wehave our Make your Mark annual
(04:22):
conference, which will be comingup September 21st to 24th.
That's going to be in Denver,colorado.
Registration is still open soyou can head over to the Acuna
website and come make your markwith us.
And then, if you're looking foradditional opportunities
outside of our in-person events,we have our numerous networks.
Yesterday was our Q2underwriting network meeting, so
(04:45):
if you were able to attend that, then you already know how
amazing that session was.
But our marketing networks,young professional networks,
volume-based networks and thenagain our underwriting network
have quarterly meetings comingup in the next few months.
So just pay attention to theAcuma site and social feeds as
(05:06):
those events get announced.
Boy, do we have a lot going on?
We sure do Just a little bit,but it's fun, it's exciting.
I think that watching thesenetworks especially grow I mean,
our volume base for Q2 is justamazing.
To see the amount of discussionthat happens in these virtual
meetings is nothing short ofamazing, because we get to see
(05:29):
it on site.
We get to see them all light upand come to life, but now we're
getting to offer that to themon a quarterly basis as well.
Yep, couldn't agree more.
I appreciate you.
Yes, sir, thank you.
Speaker 3 (05:41):
Thank you.
All right, michael.
On to you.
Yes, sir, thank you.
Thank you, all right, michael.
On to you.
Now, again, we want to focus oncompliance, but I have to stay
to the heart of this podcast.
So first things first.
The same boilerplate,boilerplate question.
I always ask everybody you knowthe reason for why we are here.
(06:01):
You know who is MichaelChristians, so that's always
going to be the first question.
So first things here.
Who is Michael Christians?
So that's always going to bethe first question.
So first things first.
Who is Michael Christians?
As I mentioned in my long-windedintro, you are a massive
supporter of the Credit Unionmovement.
You're an expert in your field,but a lot of people don't know
you, which is shocking.
They may not know you.
(06:22):
You are a regular at our events.
You spoke at our workshops.
You're going to be speaking atour annual conference.
You've spoken at tons of ourwebinars.
You've written articles for thepipeline.
You're going to write morearticles for the pipeline.
You are the brains behind ourAcuma compliance insights.
So for those of you who havenot seen your name or last name
(06:45):
pop up somewhere in dealing withAcuma because they're not just
paying attention who is MichaelChristians?
Speaker 5 (06:55):
Well, and it's maybe not that they don't know who I
am, but they just don't want toknow who I am.
Right, but no.
So you know, I've been, I'vebeen doing this a while.
Um, I've been in the financialservices space, uh, for, you
(07:16):
know, over 20 years.
I got into the compliancespecific gig, um, you know, just
briefly, uh, before I got, wentback to law school back in, uh,
2010, 2011,.
Came out of there and reallykind of landed in the credit
union movement and have stayedthere and, uh, you know, been
(07:42):
working with Acuma for a numberof years, do a lot in the
mortgage lending space.
You know, over time, you knowwhat, what your team is doing
Peter, you know, justin, krista,uh, the gang, um, it's, it's
(08:11):
phenomenal.
The workshops that you puttogether, the annual event, um,
you know, there's just this is agreat, great uh resource for
credit unions in the mortgagelending space, which, you know,
when we talk about compliance,that's what it's all about.
(08:31):
Right, no one can be a 100%expert on this.
You got to lean on your friendsand so we're all in this
together and I'm happy to playmy part.
Speaker 3 (08:43):
No well, I appreciate the kind words.
You know, it's like you said,we're all in this together and
I'm happy to play my part.
No well, I appreciate the kindwords.
You know, it's like you said,we're all in this together, and
so that's why we, you know, goout and we find people like you,
because we need people like you, who are the best and brightest
in our industry to kind ofeducate our members, and
(09:06):
brightest in our industry tokind of educate our members,
because when you look at theaverage credit union, the
average credit union doesn'thave the resources to have this
internal knowledge.
I mean, I was there and it wasalways a head scratcher, right?
So how do we navigate thesetrying times?
And I think that's a perfectsegue to, you know, the main
(09:27):
reason why we're here.
So I'm a frame up the theminiseries as briefly as I
possibly can, more so than I didin my intro.
So each episode is going to befocused on a specific topic
that's impacting our members,right, and I'm not going to give
our listeners anything morethan that.
(09:48):
But with the exception to yourepisode, your episode, more so,
is going to focus on a generaloverview of all topics that are
impacting them, because we feltit important to kind of start
off with a list, a list of everyimportant compliance topic.
(10:12):
Now, it's safe to say thatthroughout the miniseries, that
one or more of these items willbe discussed by every other
single, every single one of theother experts that we have, but
because there's so many other,so because there's so many
topics going on, we were goingto betray our listeners by not
(10:36):
addressing one or multiple onesat some point.
So so, michael, here we go.
We're going to start off withjust a list of items that our
members really should be focusedon.
Now, in many ways, you do thisfor us all the time, like you
(10:56):
come to our events and you kindof just hit it from the top down
these are the things you needto pay attention to.
So let's start from the top.
What if you had to say this ismy number one thing, number one,
compliance hit list.
What is that number one thingthat our members really need to
(11:20):
start paying attention to?
Speaker 5 (11:20):
Yeah, so I think what we need to focus on is not
having a false sense of securityin this time where, yes, we are
seeing federal regulatoryagencies, whether that be the
(11:43):
CFPB, the NCUA, etc.
Taking a significant backseat,comparatively speaking to where.
Don't have that false sense ofsecurity.
Just because there's not atremendous amount of new
(12:16):
regulation coming out right nowdoesn't mean that there's not a
lot still going on.
And you know, I think we'regoing to spend some time talking
about, just generally, whatwe're doing right now is seeing
us unwind a lot of what we'vedone over the past few years.
(12:42):
This is a very important timefor us as an industry to reset
and say, okay, the way we havedone things is maybe not
necessarily the way we're goingto do things over the course of
the next few years.
Speaker 3 (13:00):
So okay, so let's set these individual topics now.
Okay, so when we look at theseindividual topics and I topics,
you talk to a lot of creditunions.
Whether it's at events orwhether they're clients of yours
, it doesn't really matter.
When you look for areas ofopportunity for credit unions
(13:21):
and things that credit unionstend to have, we'll say the
largest blind spots to what arethey in your opinion?
Speaker 5 (13:32):
Well, you know, of course, I don't know that
there's any discussion that wecan have about compliance where
we're not going to at leastmention fair lending.
Speaker 3 (13:44):
I think that's fair.
That's a fair statement.
Speaker 5 (14:01):
You know, from a fair statement by the previous CFPB
administration, we're seeing acompletely different engagement
when it comes to redlining,where they're going to focus
more on specific evidence ofactual consumer harm versus
(14:23):
maybe basing a redlining actionon perceived harm.
You know there's also, when wethink about fair lending, we
think about three differentforms of discrimination, one of
which is known as disparateimpact, and disparate impact is
(14:45):
a theory that says impact.
And disparate impact is atheory that says, look, the
credit union has a policy or apractice from a lending
perspective that it appliesuniformly across the board, but,
for whatever reason, thatpolicy ends up having a
discriminatory effect.
It's been a recognized form ofdiscrimination for a long time.
(15:08):
We have an executive order fromthe president now that says
we're basically to continue tostay in tune with it but realize
that the way the previousadministration looked at fair
(15:36):
lending is completely differentthan what we're faced with now.
Speaker 3 (15:44):
Okay, what we're faced with now.
Okay, I mean especially withcredit unions.
Credit unions have been in thenews a lot recently with
redlining.
Right, I don't think it's goingto go away with this new
administration and it's stillsafe to say new administration
it's not going to go away withthe new CAPB, regardless of the
(16:07):
fact that McKern out steppedback about a month ago.
Um, it's we.
It's still the forefront andespecially with, you know, a
target very much still on thecredit unions, back for our
(16:28):
lending practices.
And when I say that I'm reallyfocused on, you know, bank
lobbyists, you know how we goabout lending is extremely
important.
Right, we have to show that weare going out and lending to low
(16:49):
to moderate incomes and notdiscriminating against, you know
, people.
Ie redlining, right, I meanthat up a good point.
Speaker 5 (16:59):
It's redlining or fair lending let me say it that
way Fair lending still going tobe a hot topic, still going to
be a risk.
It's just how it's going to belooked at is different, and I
think during your compliancemini-series here, you're going
(17:23):
to have a discussion about theHome Mortgage Disclosure Act,
and I think that's monumentallyimportant, because what the Home
Mortgage Disclosure Act and Ithink that's monumentally
important because what the HomeMortgage Disclosure Act does is
it provides you with the datathat indicates whether you're
reaching out to those areas thatyou just talked about, and so
credit unions are going to haveto focus in on that data and do
(17:48):
some self-assessment, if youwill, because now we know
definitively that it's that datathat's going to generate how
large that target is on us,right?
Speaker 3 (18:03):
100%, yep, 100%, yep, right.
So I mean, and that's the youknow, you know we, we talked
about it.
You know we didn't talk aboutso much on on this podcast, but
we've talked about in the past.
You know, although there's, youknow, fair lending there,
there's, there's, you know,redlining, and you know there's
ecoa, you know, all too oftenyou, you have these rules,
(18:28):
regulations, acts, they all holdhands together, they all
overlap and there's a reason forthat.
You know, they all, in manyways, are built for, you know,
to prevent anti-predatorylending practices in some way,
shape or form.
Right, you know, and it doesn'tjust stop there.
(18:52):
Right, we have to focus ondoing the right thing at any
given time, and now more thanever, with the data that is out
there.
If you don't understand theserules, regulations, do you name
it?
Someone else does better thanyou.
(19:15):
So, going back to your point,leveraging that data is vital in
this day and age.
Speaker 5 (19:24):
You know and let's stay on the topic of fairness
here for just a minute, becauseI think that's a good way to say
it you know, when we obviouslyfair lending is, of course,
about fairness, but let's talk alittle bit about, you know,
things that maybe were, excuseme, considered by the previous
(19:49):
administration to be unfair,deceptive.
Speaker 3 (19:53):
You're talking about UDEP.
Speaker 5 (19:55):
UDEP.
That's exactly right, and Ithink we're going to see a
change there too.
You know, we've seen the CFPBcame out.
(20:29):
Oh, I don't know.
The CFPB came out, oh, I don'tknow.
Just, I think it was publishedwithin theicing space related to
, say, cancellation of privatemortgage insurance or loss
mitigation options or pay-to-payfees.
Whatever the case may be, Ithink we still have to be aware
(21:03):
of that element of unfairness,because, even though maybe the
CFPB and CUA you know, once allof that shakes out, maybe
they're going to take a backseat, I think what we have to be
very aware of is that somebody'sgoing to probably step up and
fill that void, and you knowwhat that's going to be.
(21:24):
That's going to be your stateregulators, that's going to be
your state regulators, that'sgoing to be your state attorneys
general.
(21:44):
It's still out there.
You need to understand it, youneed to stay on top of it,
because maybe the CFPB doesn'tmake it a priority, but somebody
else probably will, right?
Speaker 3 (22:01):
And so sticking with UDAP.
So I mean, obviously there's alot of change with UDAP Right,
with udap.
So I mean obviously there's alot of change with udap right
and, and you know so udap, youknow, obviously udap for a long
period of time was somethingthat was highly debated.
You know the definition of udap, right, yeah, but, but udap can
(22:21):
go towards a lending practicein general, right, what is
considered unfair and what isconsidered deceptive.
So it can really be both.
If I understand it correctly,it can go anywhere from the type
of loan you give someone to thepricing you give someone, to
(22:48):
who gets what and versus anotherperson gets what, correct.
So it pretty much it almostcovers the full spectrum of how
and what and why we do stuff.
Am I understanding that right?
Like, as far as like, it's likea full, blanket statement for
ecoa, fair lending and you nameit like it, it's almost, it's,
(23:11):
it's come almost like a blanketterm yeah, yeah, I mean I.
Speaker 5 (23:15):
I think you're 100 correct on that, because there
is not a corner of your creditunion's mortgage lending
operation that is not subject tothis discussion about UDAP.
It could include anything fromhow you advertise your mortgage
(23:35):
products and services to thefair lending implications of you
know.
How are you evaluating yourapplicants?
How are you making yourorigination decisions?
How are you servicing the loanafter it's on the books?
(23:56):
How are you attempting tocollect the debt is not, there's
, there's, there's not a cornerof the credit union that is
(24:16):
immune from this scrutiny.
Speaker 3 (24:17):
When it comes to udep , you're 100 accurate, so, okay.
So this may come off like asilly question, right?
So let's say I'm gonna focus onmarketing, right?
So in marketing, you have theidea of the rate and disclosing
it as an APR, right, gramm-leach, right, yep?
But let's say, hypotheticallyspeaking, when you get to the
(24:41):
actual application process,someone doesn't qualify at that
rate for whatever reason, right,yep?
And let's say there's actuallya real violation.
Okay, does that fall underneathof, underneath, a violation of?
(25:02):
And let's say that,hypothetically speaking, that
was the APR quoted on themarketing material was not
accurate.
Does that?
Is that a violation of GrahamLeach, or is that a violation?
Is that UDAB?
Like, at what point does is, isit?
Do all these things startoverlapping?
(25:23):
At what point in time does onetrump another?
I hate to use that terminology,but you get what I'm saying no,
I do and and and I think itcould be both.
Speaker 5 (25:31):
You know in all honesty, and and here here's the
best way to look at udDEP We'vegot some very specific
advertising requirements underReg Z specific to mortgage loans
.
Now we could have a violationunder Reg Z where we potentially
(25:55):
disclosed an APR incorrectly.
We didn't include an additionaldisclosure when there was a
trigger term present, whateverthe case may be, but surrounding
all of that is this overarchingconcept of deceptiveness which
(26:16):
is a component of UDAP.
If your advertisement isdeceptive to the point where a
reasonable person could not beexpected to understand, that's
what you meant.
That's an issue and I think wehave to be very careful because
(26:41):
you and I standing here talkingabout this, we can throw a lot
of terms, we can throw a lot ofwords around that you and I and
most of our listeners understandbecause they're terms of the
trade, understand becausethey're terms of the trade.
It's our business, we know whatthose terms mean.
(27:02):
There's still 70, 75, 80% ofthe alphabet regulation side of
a strictly true complianceviolation to just this
overarching concept of that'sdeceptive.
Speaker 3 (27:38):
And as a result of the deceptiveness, here's your
potential for consumer harm.
I know I'm sticking with youbecause I just find it
fascinating.
So does you build in the factor have any leniency for
technical error, like Trid does?
Nope, nope.
Speaker 5 (27:55):
It does Really.
It really doesn't, because ifyou look at it doesn't from a
unfairness perspective, theinterpretation of UDAP is that
it doesn't necessarily have tobe actual consumer harm.
It can simply be the risk ofconsumer harm From a
(28:18):
deceptiveness perspective.
It doesn't have to be that amajority of the general public
doesn't understand youradvertisement or your disclosure
.
It's the reasonable personstandard.
And Peter, let me tell you thereasonable person standard in
(28:40):
the eyes of the law that's not avery high bar to cross, right.
It's certainly not.
So, yeah, there's just there'snot a lot of protection when it
comes to UDAP, and so you know,I just again I want to go back
(29:00):
to just because our federalregulators are maybe taking a
step back.
If there is potential consumerharm that still exists which
there is when we're talkingabout unfairness and
deceptiveness somebody's goingto step up and somebody's going
(29:27):
to carry that torch to protectthe consumer.
So don't think that we can goback to the wild, wild west
because we can't.
Speaker 3 (29:35):
And it's going to be one of those states like New
York, california, absolutely andor it could be one of those
states like Alabama or Georgiathey're the ones who have a long
history of redlining ECOAenforcement.
(29:56):
It's going to be one of thosestates, but I start with New
York and California, becausethey pretty much have their own
mini CBBs.
Speaker 5 (30:05):
That's right.
Speaker 3 (30:06):
But I guess we'll see .
I mean, udap is fascinating.
It just really is.
You know we're approaching thattime because these are meant to
be quick hits.
But if you could quicklysummarize just some other ones
real quick, other massivecompliance topics that our
members really need to, ourmembers and listeners really
(30:27):
need to hit on what, would theybe Just real quick.
Speaker 5 (30:31):
Yeah, you know just a couple of real quick ones.
I want to stay in the EqualCredit Opportunity Act space.
Stay in the Equal CreditOpportunity Act space.
I want to talk about adverseaction requirements and making
sure that we are clearlydisclosing to applicants when
(30:53):
we're not able to provide themthe credit that they requested.
We give them specific reasonsas to why.
I see a lot of credit unionsthat want to say well, you know,
you didn't meet our minimumcredit score requirement.
Well, that doesn't help theconsumer, right?
(31:14):
The expectation is that theadverse action requirements
exist to make sure that anapplicant knows what do I have
to do to put myself in a betterposition next time?
And I think that's veryimportant for credit unions,
because that's really that's thebusiness model that we're built
(31:34):
on right.
We are partners with ourmembers, so pay attention to
that.
And the other thing would bemortgage servicing.
Whether that be loss mitigation, early intervention, whatever
the case may be, you've got tokeep in mind that you have
(31:55):
compliance responsibilities thatcontinue after origination for
the life of the loan.
Speaker 3 (32:04):
Okay, you know, I was looking at some of our notes,
you know, just a second ago, andthe funny thing is is that one
of the things that kind ofbrings me me back to what you
just said is is failing toterminate PMI on time, and the
(32:25):
number of servicers that are notdoing that Is amazing.
Speaker 5 (32:33):
It is.
It's it's shocking because it'sreally.
I mean, it's a relativelysimple calculation and
monitoring and it's just it'snot happening.
And you want to talk aboutconsumer harm?
Well, yeah, if I'm having tocontinue to pay private mortgage
insurance premiums for anadditional 18 months beyond what
(32:57):
the law permits.
Well, you know, it doesn't takea very strong argument in a
court of law that there's beenconsumer harm there.
Speaker 3 (33:15):
And you know I won't name the servicer that he's with
, but he's with a servicer andthat servicer has a Zillow
estimate on.
You know, when you log in, ifyou log in, you have the Zillow
estimate displayed.
This is what your house isworth and of course you see what
(33:39):
your current balance is.
And just strictly based off ofthat, he was at like a 65 ltv
and he's still a pmi.
I was like he's like can I, canI drop this pma?
I was like it should haveautomatically dropped off.
Absolutely.
I was like you've had thishouse for four years.
It should have automaticallydropped off.
I was like like, call them, getit removed.
(34:02):
So we did.
Speaker 5 (34:04):
Yeah, it's.
I, I don't know, I mean, that'sthat?
That's been one of those thingsthat, um, it just doesn't seem
to be getting a whole lot better.
But you know, again, we, we do.
In summary, yeah, it's adifferent, it's a it's a
different regulatory environmenttoday than it has been.
(34:26):
There's no question about that.
But don't take your eye off theball.
Speaker 3 (34:31):
I agree.
All right, we need to starttransitioning, but before we do,
as always, I ask the same exactlast question, and it's the
same first question, same lastquestion.
The same last question is youknow what keeps you going, what
keeps you motivated?
You're very passionate aboutour industry.
(34:53):
As many credit unions as youpossibly can you know,
understand compliance andregulations and a simple to as,
as and as simply as theypossibly can.
But what keeps you going?
Speaker 5 (35:09):
yeah, I think it goes back to one of the very first
things that you said.
Um, you know credit unions,depending on their size, you
don't have large departments todeal with this.
You're lucky if you've got acompliance officer, and it
(35:32):
really does take a village.
Take a village.
You need to be able to rely onpeers, on experts in the field,
to really kind of help younavigate a very complex
environment.
And I, you know, I love doingthat, I love helping credit
(35:56):
unions, I love being a resource.
Um, you know, and and andthat's why I uh am so actively
involved, uh, with, with Acuma,because that's what we're trying
to do, right, that's what allof us are trying to do is to
help each other, um, navigated avery again complex, very
(36:21):
complex topic perfect.
Speaker 3 (36:23):
Love it, man, love it all.
Right, michael cypress.
Transition to the secondsegment of our podcast, my
favorite.
Just like we did last year withour mini series, this year's,
this summer's miniseries isgoing to be all focused on dad
jokes.
I know you came prepared, wellprepared, so you came prepared
(36:45):
before, but we're only going todo two, I'm sorry.
So here's what we're going todo Michael, you're going to do
two, the Hawk's going to do twoand I'll wrap up with two.
So, michael, when you are ready, please give us your two dad
jokes.
Speaker 5 (37:03):
So you know, let me, let me just say this this is
it's a very intimidating.
It's a very intimidating to tryand go up against you guys with
dad jokes.
So I'm going to do my best.
No, no, no.
Speaker 3 (37:16):
Awesome.
Why was the computer so coldwith dad jokes.
So I'm going to do my best, no,no, no, it's going to be
awesome.
Speaker 5 (37:19):
Why was the computer so cold?
Speaker 3 (37:26):
Why.
Speaker 5 (37:28):
It left its windows open.
Speaker 3 (37:31):
I hate that.
I knew that I hate that.
Speaker 5 (37:36):
Here's I'm going for pro care.
This, I think, is my best one.
We'll see what did the nuts saywhen it sneezed cashew, but you
gotta put something into it.
(37:56):
Cashew, cashew.
But you gotta put somethinginto it, you gotta, that's right
.
That's what I got, boys, that'swhat I got that was good.
Speaker 2 (38:09):
Which hand is better to write?
With the right one?
Neither it's better to writewith a pen.
Speaker 5 (38:22):
I like that one.
Speaker 3 (38:26):
I love my like the ones I find that are not really
like punchy jokes but like it'slike for a while, for a while he
had jokes that were all like mypen.
Speaker 2 (38:38):
Yeah, those are my favorite.
Um, For a while he had jokesthat were all like my pen.
Yeah, sefty, those are myfavorite.
All right, so another one ishow do cows stay up to date with
current events?
This one might have been done.
The moose paper yeah, that'swhat I thought.
That one, the moose paper yeah,that's what I thought.
Speaker 5 (39:01):
That one, your first one, that redeems you.
Speaker 2 (39:06):
I started strong, I finished strong.
Speaker 3 (39:10):
Sorry guys, my turn.
Or did you want to redeemyourself?
Speaker 2 (39:16):
No, no, no, we're going to get both of yours, so
that way.
Speaker 3 (39:22):
Well, see, mine aren't like that, mine are more
like one-liners.
Oh okay, well, let's go, let'shave them All right.
As you guys know, I love goingoutdoors.
It's much safer than going outwindows.
Speaker 5 (39:42):
Yeah, it's much safer than going out windows.
Yeah, that silence is for areason no, whatever.
Speaker 3 (39:48):
Okay, I have my last one.
I'm having a hard time gettingthe yoga instructor I hired out
of my house.
Every time I ask him, he saysnamaste.
Speaker 2 (40:05):
That was a good one All right.
Speaker 3 (40:07):
Well, that wraps up this compliance episode mini
series dad jokes.
Michael, thank you very muchfor your time, as always, and
again, thank you for everythingthat you do for for Acuma, our
community and our industry.
Speaker 5 (40:23):
Good to be with you, gentlemen.
Speaker 3 (40:24):
Thank you.
Speaker 2 (40:25):
Of course.
Speaker 3 (40:26):
And Justin.
Thank you, of course, it was mypleasure.
And, to close out, thank youagain to Consolidated Analytics
for sponsoring today's episodeand to all of you.
We know your time is valuable.
Thank you for tuning in to thelatest episode of Acuma's On
Point podcast.
We hope you enjoyed it.
Until next time.
Be well, my friends.
Speaker 1 (40:45):
Thanks for listening.
We'll see you next time at theAcuma On Point podcast.
If not already, be sure tosubscribe and give us a
five-star rating For more greatepisodes and information.
Be sure to visit us online atacumaorg and get the latest
updates head over to ourlinkedin page.
The views and opinions expressed in this
podcast do not necessarilyreflect the views or positions
of Acuma, its board of directors, its management staff or its
members.
The podcast discussionpresented is conversational in
nature and for generalinformation only.
Speaker 3 (00:32):
Hello and welcome to Active Zone Point Podcast, a
series focused on sharing thestories of people who are making
a positive impact in the creditunion mortgage industry.
I'm your host, Peter Benjamin.
Before we get to our episode,just a quick word from our
sponsor.
Speaker 4 (00:42):
This episode is brought to you by Consolidated
Analytics, helping credit unionsmake smarter mortgage decisions
, from origination to servicingand beyond.
With expert valuation, riskmanagement and compliance
solutions, they provide theinsights you need to protect
your members and grow yourportfolio with confidence.
Whether it's due diligence orcollateral risk assessment, they
(01:03):
help you navigate the marketwith ease.
Learn more atConsolidatedAnalyticscom.
Speaker 3 (01:08):
Welcome to the first episode of our Compliance Summer
Miniseries, where each episodewill feature an intimate
conversation with people who Iconsider to be experts in their
field and supporters of thecredit union movement.
It's our goal with theseepisodes to take a deep dive
into various compliance topicsthat are impacting and reshaping
the credit union mortgageindustry.
(01:29):
Our first guest in thecompliance miniseries is our
friend, michael Christians.
Regulatory Compliance Counselwith Michael Christians
Consulting LLC.
Michael, my friend, how are youdoing today?
Peter?
Speaker 5 (01:43):
I'm doing well.
It's great to be with you.
Thank you for the invitationand, yeah, I imagine we've got
some things to talk about, don'twe?
Speaker 3 (01:54):
I mean one.
It's never boring with you.
It's compliance.
Compliance is a broad topictopic and it overlaps with a lot
of different things.
You could easily say compliance, you could say policy, you
could say regulations, all ofthe above.
They're like triplets runningdown the street holding hands.
(02:17):
So it really is this massivetopic.
It's one of my favorite thingsto discuss because it's this
weird anomaly of a thing that noone ever seems to get right.
You know, as funny as it sounds, you and I could read something
you know 10 times and interpretit completely differently.
(02:40):
Yep, and that's all it is.
Speaker 5 (02:43):
It's all up for interpretation and, and to that
point um, both of ourinterpretations, although
completely different, areprobably accurate to some extent
right, that's exactly it.
Speaker 3 (02:54):
That's exactly.
And the funny thing is is thatwhen they write these rules,
they purposely leave, like thesegray areas, sure, and so that's
why we're doing this.
You know, the summer miniseriesspecifically focus on
compliance with the hopes thatwe shed some light on the gray
areas.
(03:14):
Now, before we get to the meatand potatoes, like we always do,
got to bring Justin in.
Justin the hawk, the screechsound just went off.
I'm not gonna do it again.
But, justin, how are you doingtoday?
And please tell us what is thelatest and greatest happening
over at acuma?
Speaker 2 (03:35):
I'm good, peter.
How are you living?
The dream man, that's good.
I'm glad that you also didn'ttry to make that hawk sound
again that was did it once andI'm never, ever, ever going to
do it again.
Yeah, I mean, you just got to gowith the caca.
That's the call of the day atthat point.
You're not cool enough.
That's what it is.
You don't have the namesake tobe able to do it, that's okay.
(04:00):
Anyways, we just got back fromSeattle last week.
That was super exciting.
It was great to see all of ourmembers engaging and interacting
with each other.
That rounded out our focalpoint workshops.
So if you missed them, youmissed some great events.
That's all I'm going to say.
They were good, they werefantastic.
So up next, for in-person, wehave our Make your Mark annual
(04:22):
conference, which will be comingup September 21st to 24th.
That's going to be in Denver,colorado.
Registration is still open soyou can head over to the Acuna
website and come make your markwith us.
And then, if you're looking foradditional opportunities
outside of our in-person events,we have our numerous networks.
Yesterday was our Q2underwriting network meeting, so
(04:45):
if you were able to attend that, then you already know how
amazing that session was.
But our marketing networks,young professional networks,
volume-based networks and thenagain our underwriting network
have quarterly meetings comingup in the next few months.
So just pay attention to theAcuma site and social feeds as
(05:06):
those events get announced.
Boy, do we have a lot going on?
We sure do Just a little bit,but it's fun, it's exciting.
I think that watching thesenetworks especially grow I mean,
our volume base for Q2 is justamazing.
To see the amount of discussionthat happens in these virtual
meetings is nothing short ofamazing, because we get to see
(05:29):
it on site.
We get to see them all light upand come to life, but now we're
getting to offer that to themon a quarterly basis as well.
Yep, couldn't agree more.
I appreciate you.
Yes, sir, thank you.
Speaker 3 (05:41):
Thank you.
All right, michael.
On to you.
Yes, sir, thank you.
Thank you, all right, michael.
On to you.
Now, again, we want to focus oncompliance, but I have to stay
to the heart of this podcast.
So first things first.
The same boilerplate,boilerplate question.
I always ask everybody you knowthe reason for why we are here.
(06:01):
You know who is MichaelChristians, so that's always
going to be the first question.
So first things here.
Who is Michael Christians?
So that's always going to bethe first question.
So first things first.
Who is Michael Christians?
As I mentioned in my long-windedintro, you are a massive
supporter of the Credit Unionmovement.
You're an expert in your field,but a lot of people don't know
you, which is shocking.
They may not know you.
(06:22):
You are a regular at our events.
You spoke at our workshops.
You're going to be speaking atour annual conference.
You've spoken at tons of ourwebinars.
You've written articles for thepipeline.
You're going to write morearticles for the pipeline.
You are the brains behind ourAcuma compliance insights.
So for those of you who havenot seen your name or last name
(06:45):
pop up somewhere in dealing withAcuma because they're not just
paying attention who is MichaelChristians?
Speaker 5 (06:55):
Well, and it's maybe not that they don't know who I
am, but they just don't want toknow who I am.
Right, but no.
So you know, I've been, I'vebeen doing this a while.
Um, I've been in the financialservices space, uh, for, you
(07:16):
know, over 20 years.
I got into the compliancespecific gig, um, you know, just
briefly, uh, before I got, wentback to law school back in, uh,
2010, 2011,.
Came out of there and reallykind of landed in the credit
union movement and have stayedthere and, uh, you know, been
(07:42):
working with Acuma for a numberof years, do a lot in the
mortgage lending space.
You know, over time, you knowwhat, what your team is doing
Peter, you know, justin, krista,uh, the gang, um, it's, it's
(08:11):
phenomenal.
The workshops that you puttogether, the annual event, um,
you know, there's just this is agreat, great uh resource for
credit unions in the mortgagelending space, which, you know,
when we talk about compliance,that's what it's all about.
(08:31):
Right, no one can be a 100%expert on this.
You got to lean on your friendsand so we're all in this
together and I'm happy to playmy part.
Speaker 3 (08:43):
No well, I appreciate the kind words.
You know, it's like you said,we're all in this together and
I'm happy to play my part.
No well, I appreciate the kindwords.
You know, it's like you said,we're all in this together, and
so that's why we, you know, goout and we find people like you,
because we need people like you, who are the best and brightest
in our industry to kind ofeducate our members, and
(09:06):
brightest in our industry tokind of educate our members,
because when you look at theaverage credit union, the
average credit union doesn'thave the resources to have this
internal knowledge.
I mean, I was there and it wasalways a head scratcher, right?
So how do we navigate thesetrying times?
And I think that's a perfectsegue to, you know, the main
(09:27):
reason why we're here.
So I'm a frame up the theminiseries as briefly as I
possibly can, more so than I didin my intro.
So each episode is going to befocused on a specific topic
that's impacting our members,right, and I'm not going to give
our listeners anything morethan that.
(09:48):
But with the exception to yourepisode, your episode, more so,
is going to focus on a generaloverview of all topics that are
impacting them, because we feltit important to kind of start
off with a list, a list of everyimportant compliance topic.
(10:12):
Now, it's safe to say thatthroughout the miniseries, that
one or more of these items willbe discussed by every other
single, every single one of theother experts that we have, but
because there's so many other,so because there's so many
topics going on, we were goingto betray our listeners by not
(10:36):
addressing one or multiple onesat some point.
So so, michael, here we go.
We're going to start off withjust a list of items that our
members really should be focusedon.
Now, in many ways, you do thisfor us all the time, like you
(10:56):
come to our events and you kindof just hit it from the top down
these are the things you needto pay attention to.
So let's start from the top.
What if you had to say this ismy number one thing, number one,
compliance hit list.
What is that number one thingthat our members really need to
(11:20):
start paying attention to?
Speaker 5 (11:20):
Yeah, so I think what we need to focus on is not
having a false sense of securityin this time where, yes, we are
seeing federal regulatoryagencies, whether that be the
(11:43):
CFPB, the NCUA, etc.
Taking a significant backseat,comparatively speaking to where.
Don't have that false sense ofsecurity.
Just because there's not atremendous amount of new
(12:16):
regulation coming out right nowdoesn't mean that there's not a
lot still going on.
And you know, I think we'regoing to spend some time talking
about, just generally, whatwe're doing right now is seeing
us unwind a lot of what we'vedone over the past few years.
(12:42):
This is a very important timefor us as an industry to reset
and say, okay, the way we havedone things is maybe not
necessarily the way we're goingto do things over the course of
the next few years.
Speaker 3 (13:00):
So okay, so let's set these individual topics now.
Okay, so when we look at theseindividual topics and I topics,
you talk to a lot of creditunions.
Whether it's at events orwhether they're clients of yours
, it doesn't really matter.
When you look for areas ofopportunity for credit unions
(13:21):
and things that credit unionstend to have, we'll say the
largest blind spots to what arethey in your opinion?
Speaker 5 (13:32):
Well, you know, of course, I don't know that
there's any discussion that wecan have about compliance where
we're not going to at leastmention fair lending.
Speaker 3 (13:44):
I think that's fair.
That's a fair statement.
Speaker 5 (14:01):
You know, from a fair statement by the previous CFPB
administration, we're seeing acompletely different engagement
when it comes to redlining,where they're going to focus
more on specific evidence ofactual consumer harm versus
(14:23):
maybe basing a redlining actionon perceived harm.
You know there's also, when wethink about fair lending, we
think about three differentforms of discrimination, one of
which is known as disparateimpact, and disparate impact is
(14:45):
a theory that says impact.
And disparate impact is atheory that says, look, the
credit union has a policy or apractice from a lending
perspective that it appliesuniformly across the board, but,
for whatever reason, thatpolicy ends up having a
discriminatory effect.
It's been a recognized form ofdiscrimination for a long time.
(15:08):
We have an executive order fromthe president now that says
we're basically to continue tostay in tune with it but realize
that the way the previousadministration looked at fair
(15:36):
lending is completely differentthan what we're faced with now.
Speaker 3 (15:44):
Okay, what we're faced with now.
Okay, I mean especially withcredit unions.
Credit unions have been in thenews a lot recently with
redlining.
Right, I don't think it's goingto go away with this new
administration and it's stillsafe to say new administration
it's not going to go away withthe new CAPB, regardless of the
(16:07):
fact that McKern out steppedback about a month ago.
Um, it's we.
It's still the forefront andespecially with, you know, a
target very much still on thecredit unions, back for our
(16:28):
lending practices.
And when I say that I'm reallyfocused on, you know, bank
lobbyists, you know how we goabout lending is extremely
important.
Right, we have to show that weare going out and lending to low
(16:49):
to moderate incomes and notdiscriminating against, you know
, people.
Ie redlining, right, I meanthat up a good point.
Speaker 5 (16:59):
It's redlining or fair lending let me say it that
way Fair lending still going tobe a hot topic, still going to
be a risk.
It's just how it's going to belooked at is different, and I
think during your compliancemini-series here, you're going
(17:23):
to have a discussion about theHome Mortgage Disclosure Act,
and I think that's monumentallyimportant, because what the Home
Mortgage Disclosure Act and Ithink that's monumentally
important because what the HomeMortgage Disclosure Act does is
it provides you with the datathat indicates whether you're
reaching out to those areas thatyou just talked about, and so
credit unions are going to haveto focus in on that data and do
(17:48):
some self-assessment, if youwill, because now we know
definitively that it's that datathat's going to generate how
large that target is on us,right?
Speaker 3 (18:03):
100%, yep, 100%, yep, right.
So I mean, and that's the youknow, you know we, we talked
about it.
You know we didn't talk aboutso much on on this podcast, but
we've talked about in the past.
You know, although there's, youknow, fair lending there,
there's, there's, you know,redlining, and you know there's
ecoa, you know, all too oftenyou, you have these rules,
(18:28):
regulations, acts, they all holdhands together, they all
overlap and there's a reason forthat.
You know, they all, in manyways, are built for, you know,
to prevent anti-predatorylending practices in some way,
shape or form.
Right, you know, and it doesn'tjust stop there.
(18:52):
Right, we have to focus ondoing the right thing at any
given time, and now more thanever, with the data that is out
there.
If you don't understand theserules, regulations, do you name
it?
Someone else does better thanyou.
(19:15):
So, going back to your point,leveraging that data is vital in
this day and age.
Speaker 5 (19:24):
You know and let's stay on the topic of fairness
here for just a minute, becauseI think that's a good way to say
it you know, when we obviouslyfair lending is, of course,
about fairness, but let's talk alittle bit about, you know,
things that maybe were, excuseme, considered by the previous
(19:49):
administration to be unfair,deceptive.
Speaker 3 (19:53):
You're talking about UDEP.
Speaker 5 (19:55):
UDEP.
That's exactly right, and Ithink we're going to see a
change there too.
You know, we've seen the CFPBcame out.
(20:29):
Oh, I don't know.
The CFPB came out, oh, I don'tknow.
Just, I think it was publishedwithin theicing space related to
, say, cancellation of privatemortgage insurance or loss
mitigation options or pay-to-payfees.
Whatever the case may be, Ithink we still have to be aware
(21:03):
of that element of unfairness,because, even though maybe the
CFPB and CUA you know, once allof that shakes out, maybe
they're going to take a backseat, I think what we have to be
very aware of is that somebody'sgoing to probably step up and
fill that void, and you knowwhat that's going to be.
(21:24):
That's going to be your stateregulators, that's going to be
your state regulators, that'sgoing to be your state attorneys
general.
(21:44):
It's still out there.
You need to understand it, youneed to stay on top of it,
because maybe the CFPB doesn'tmake it a priority, but somebody
else probably will, right?
Speaker 3 (22:01):
And so sticking with UDAP.
So I mean, obviously there's alot of change with UDAP Right,
with udap.
So I mean obviously there's alot of change with udap right
and, and you know so udap, youknow, obviously udap for a long
period of time was somethingthat was highly debated.
You know the definition of udap, right, yeah, but, but udap can
(22:21):
go towards a lending practicein general, right, what is
considered unfair and what isconsidered deceptive.
So it can really be both.
If I understand it correctly,it can go anywhere from the type
of loan you give someone to thepricing you give someone, to
(22:48):
who gets what and versus anotherperson gets what, correct.
So it pretty much it almostcovers the full spectrum of how
and what and why we do stuff.
Am I understanding that right?
Like, as far as like, it's likea full, blanket statement for
ecoa, fair lending and you nameit like it, it's almost, it's,
(23:11):
it's come almost like a blanketterm yeah, yeah, I mean I.
Speaker 5 (23:15):
I think you're 100 correct on that, because there
is not a corner of your creditunion's mortgage lending
operation that is not subject tothis discussion about UDAP.
It could include anything fromhow you advertise your mortgage
(23:35):
products and services to thefair lending implications of you
know.
How are you evaluating yourapplicants?
How are you making yourorigination decisions?
How are you servicing the loanafter it's on the books?
(23:56):
How are you attempting tocollect the debt is not, there's
, there's, there's not a cornerof the credit union that is
(24:16):
immune from this scrutiny.
Speaker 3 (24:17):
When it comes to udep , you're 100 accurate, so, okay.
So this may come off like asilly question, right?
So let's say I'm gonna focus onmarketing, right?
So in marketing, you have theidea of the rate and disclosing
it as an APR, right, gramm-leach, right, yep?
But let's say, hypotheticallyspeaking, when you get to the
(24:41):
actual application process,someone doesn't qualify at that
rate for whatever reason, right,yep?
And let's say there's actuallya real violation.
Okay, does that fall underneathof, underneath, a violation of?
(25:02):
And let's say that,hypothetically speaking, that
was the APR quoted on themarketing material was not
accurate.
Does that?
Is that a violation of GrahamLeach, or is that a violation?
Is that UDAB?
Like, at what point does is, isit?
Do all these things startoverlapping?
(25:23):
At what point in time does onetrump another?
I hate to use that terminology,but you get what I'm saying no,
I do and and and I think itcould be both.
Speaker 5 (25:31):
You know in all honesty, and and here here's the
best way to look at udDEP We'vegot some very specific
advertising requirements underReg Z specific to mortgage loans
.
Now we could have a violationunder Reg Z where we potentially
(25:55):
disclosed an APR incorrectly.
We didn't include an additionaldisclosure when there was a
trigger term present, whateverthe case may be, but surrounding
all of that is this overarchingconcept of deceptiveness which
(26:16):
is a component of UDAP.
If your advertisement isdeceptive to the point where a
reasonable person could not beexpected to understand, that's
what you meant.
That's an issue and I think wehave to be very careful because
(26:41):
you and I standing here talkingabout this, we can throw a lot
of terms, we can throw a lot ofwords around that you and I and
most of our listeners understandbecause they're terms of the
trade, understand becausethey're terms of the trade.
It's our business, we know whatthose terms mean.
(27:02):
There's still 70, 75, 80% ofthe alphabet regulation side of
a strictly true complianceviolation to just this
overarching concept of that'sdeceptive.
Speaker 3 (27:38):
And as a result of the deceptiveness, here's your
potential for consumer harm.
I know I'm sticking with youbecause I just find it
fascinating.
So does you build in the factor have any leniency for
technical error, like Trid does?
Nope, nope.
Speaker 5 (27:55):
It does Really.
It really doesn't, because ifyou look at it doesn't from a
unfairness perspective, theinterpretation of UDAP is that
it doesn't necessarily have tobe actual consumer harm.
It can simply be the risk ofconsumer harm From a
(28:18):
deceptiveness perspective.
It doesn't have to be that amajority of the general public
doesn't understand youradvertisement or your disclosure
.
It's the reasonable personstandard.
And Peter, let me tell you thereasonable person standard in
(28:40):
the eyes of the law that's not avery high bar to cross, right.
It's certainly not.
So, yeah, there's just there'snot a lot of protection when it
comes to UDAP, and so you know,I just again I want to go back
(29:00):
to just because our federalregulators are maybe taking a
step back.
If there is potential consumerharm that still exists which
there is when we're talkingabout unfairness and
deceptiveness somebody's goingto step up and somebody's going
(29:27):
to carry that torch to protectthe consumer.
So don't think that we can goback to the wild, wild west
because we can't.
Speaker 3 (29:35):
And it's going to be one of those states like New
York, california, absolutely andor it could be one of those
states like Alabama or Georgiathey're the ones who have a long
history of redlining ECOAenforcement.
(29:56):
It's going to be one of thosestates, but I start with New
York and California, becausethey pretty much have their own
mini CBBs.
Speaker 5 (30:05):
That's right.
Speaker 3 (30:06):
But I guess we'll see .
I mean, udap is fascinating.
It just really is.
You know we're approaching thattime because these are meant to
be quick hits.
But if you could quicklysummarize just some other ones
real quick, other massivecompliance topics that our
members really need to, ourmembers and listeners really
(30:27):
need to hit on what, would theybe Just real quick.
Speaker 5 (30:31):
Yeah, you know just a couple of real quick ones.
I want to stay in the EqualCredit Opportunity Act space.
Stay in the Equal CreditOpportunity Act space.
I want to talk about adverseaction requirements and making
sure that we are clearlydisclosing to applicants when
(30:53):
we're not able to provide themthe credit that they requested.
We give them specific reasonsas to why.
I see a lot of credit unionsthat want to say well, you know,
you didn't meet our minimumcredit score requirement.
Well, that doesn't help theconsumer, right?
(31:14):
The expectation is that theadverse action requirements
exist to make sure that anapplicant knows what do I have
to do to put myself in a betterposition next time?
And I think that's veryimportant for credit unions,
because that's really that's thebusiness model that we're built
(31:34):
on right.
We are partners with ourmembers, so pay attention to
that.
And the other thing would bemortgage servicing.
Whether that be loss mitigation, early intervention, whatever
the case may be, you've got tokeep in mind that you have
(31:55):
compliance responsibilities thatcontinue after origination for
the life of the loan.
Speaker 3 (32:04):
Okay, you know, I was looking at some of our notes,
you know, just a second ago, andthe funny thing is is that one
of the things that kind ofbrings me me back to what you
just said is is failing toterminate PMI on time, and the
(32:25):
number of servicers that are notdoing that Is amazing.
Speaker 5 (32:33):
It is.
It's it's shocking because it'sreally.
I mean, it's a relativelysimple calculation and
monitoring and it's just it'snot happening.
And you want to talk aboutconsumer harm?
Well, yeah, if I'm having tocontinue to pay private mortgage
insurance premiums for anadditional 18 months beyond what
(32:57):
the law permits.
Well, you know, it doesn't takea very strong argument in a
court of law that there's beenconsumer harm there.
Speaker 3 (33:15):
And you know I won't name the servicer that he's with
, but he's with a servicer andthat servicer has a Zillow
estimate on.
You know, when you log in, ifyou log in, you have the Zillow
estimate displayed.
This is what your house isworth and of course you see what
(33:39):
your current balance is.
And just strictly based off ofthat, he was at like a 65 ltv
and he's still a pmi.
I was like he's like can I, canI drop this pma?
I was like it should haveautomatically dropped off.
Absolutely.
I was like you've had thishouse for four years.
It should have automaticallydropped off.
I was like like, call them, getit removed.
(34:02):
So we did.
Speaker 5 (34:04):
Yeah, it's.
I, I don't know, I mean, that'sthat?
That's been one of those thingsthat, um, it just doesn't seem
to be getting a whole lot better.
But you know, again, we, we do.
In summary, yeah, it's adifferent, it's a it's a
different regulatory environmenttoday than it has been.
(34:26):
There's no question about that.
But don't take your eye off theball.
Speaker 3 (34:31):
I agree.
All right, we need to starttransitioning, but before we do,
as always, I ask the same exactlast question, and it's the
same first question, same lastquestion.
The same last question is youknow what keeps you going, what
keeps you motivated?
You're very passionate aboutour industry.
(34:53):
As many credit unions as youpossibly can you know,
understand compliance andregulations and a simple to as,
as and as simply as theypossibly can.
But what keeps you going?
Speaker 5 (35:09):
yeah, I think it goes back to one of the very first
things that you said.
Um, you know credit unions,depending on their size, you
don't have large departments todeal with this.
You're lucky if you've got acompliance officer, and it
(35:32):
really does take a village.
Take a village.
You need to be able to rely onpeers, on experts in the field,
to really kind of help younavigate a very complex
environment.
And I, you know, I love doingthat, I love helping credit
(35:56):
unions, I love being a resource.
Um, you know, and and andthat's why I uh am so actively
involved, uh, with, with Acuma,because that's what we're trying
to do, right, that's what allof us are trying to do is to
help each other, um, navigated avery again complex, very
(36:21):
complex topic perfect.
Speaker 3 (36:23):
Love it, man, love it all.
Right, michael cypress.
Transition to the secondsegment of our podcast, my
favorite.
Just like we did last year withour mini series, this year's,
this summer's miniseries isgoing to be all focused on dad
jokes.
I know you came prepared, wellprepared, so you came prepared
(36:45):
before, but we're only going todo two, I'm sorry.
So here's what we're going todo Michael, you're going to do
two, the Hawk's going to do twoand I'll wrap up with two.
So, michael, when you are ready, please give us your two dad
jokes.
Speaker 5 (37:03):
So you know, let me, let me just say this this is
it's a very intimidating.
It's a very intimidating to tryand go up against you guys with
dad jokes.
So I'm going to do my best.
No, no, no.
Speaker 3 (37:16):
Awesome.
Why was the computer so coldwith dad jokes.
So I'm going to do my best, no,no, no, it's going to be
awesome.
Speaker 5 (37:19):
Why was the computer so cold?
Speaker 3 (37:26):
Why.
Speaker 5 (37:28):
It left its windows open.
Speaker 3 (37:31):
I hate that.
I knew that I hate that.
Speaker 5 (37:36):
Here's I'm going for pro care.
This, I think, is my best one.
We'll see what did the nuts saywhen it sneezed cashew, but you
gotta put something into it.
(37:56):
Cashew, cashew.
But you gotta put somethinginto it, you gotta, that's right
.
That's what I got, boys, that'swhat I got that was good.
Speaker 2 (38:09):
Which hand is better to write?
With the right one?
Neither it's better to writewith a pen.
Speaker 5 (38:22):
I like that one.
Speaker 3 (38:26):
I love my like the ones I find that are not really
like punchy jokes but like it'slike for a while, for a while he
had jokes that were all like mypen.
Speaker 2 (38:38):
Yeah, those are my favorite.
Um, For a while he had jokesthat were all like my pen.
Yeah, sefty, those are myfavorite.
All right, so another one ishow do cows stay up to date with
current events?
This one might have been done.
The moose paper yeah, that'swhat I thought.
That one, the moose paper yeah,that's what I thought.
Speaker 5 (39:01):
That one, your first one, that redeems you.
Speaker 2 (39:06):
I started strong, I finished strong.
Speaker 3 (39:10):
Sorry guys, my turn.
Or did you want to redeemyourself?
Speaker 2 (39:16):
No, no, no, we're going to get both of yours, so
that way.
Speaker 3 (39:22):
Well, see, mine aren't like that, mine are more
like one-liners.
Oh okay, well, let's go, let'shave them All right.
As you guys know, I love goingoutdoors.
It's much safer than going outwindows.
Speaker 5 (39:42):
Yeah, it's much safer than going out windows.
Yeah, that silence is for areason no, whatever.
Speaker 3 (39:48):
Okay, I have my last one.
I'm having a hard time gettingthe yoga instructor I hired out
of my house.
Every time I ask him, he saysnamaste.
Speaker 2 (40:05):
That was a good one All right.
Speaker 3 (40:07):
Well, that wraps up this compliance episode mini
series dad jokes.
Michael, thank you very muchfor your time, as always, and
again, thank you for everythingthat you do for for Acuma, our
community and our industry.
Speaker 5 (40:23):
Good to be with you, gentlemen.
Speaker 3 (40:24):
Thank you.
Speaker 2 (40:25):
Of course.
Speaker 3 (40:26):
And Justin.
Thank you, of course, it was mypleasure.
And, to close out, thank youagain to Consolidated Analytics
for sponsoring today's episodeand to all of you.
We know your time is valuable.
Thank you for tuning in to thelatest episode of Acuma's On
Point podcast.
We hope you enjoyed it.
Until next time.
Be well, my friends.
Speaker 1 (40:45):
Thanks for listening.
We'll see you next time at theAcuma On Point podcast.
If not already, be sure tosubscribe and give us a
five-star rating For more greatepisodes and information.
Be sure to visit us online atacumaorg and get the latest
updates head over to ourlinkedin page.
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