Often a mistake lenders make in response to Consumer Financial Protection Bureau guidance is to focus too narrowly on the agency’s advice. In other words, lenders and regulatory counsel sometimes focus on the details without seeing the big picture. While the CFPB did mention a number of points in connection with its mini-correspondent guidance, it expressly stated that it was not limiting its considerations to those listed. In other words, the CFPB directly stated that it would consider any factors it deemed relevant. To that end, it is important to note that the overall message – that mini-correspondents were intended as transitions, not permanent business models – means that the loan channel would be examined for consistency with the intended purpose.
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