CFPB Evidence of Compliance Development Workgroup


The mission of the CFPB Evidence of Compliance DWG is to conduct a detailed examination of the CFPB National Servicing Rule to identify and develop the necessary corresponding data structures needed to provide prima facie support for "Evidence of Compliance" with the rules.  Necessary data structures and definitions identified that do not already exist within the MISMO Reference Model will be recommended for inclusion.  In addition the team will develop an Implementation Guide to provide guidance as to how each data element corresponds to specific supporting statutory language.  The final element of this project is to begin the development of the model of how MISMO will engage and work with regulatory entities, in a forward looking manner, so as to assist in the development of industry data standards necessary for consistent reporting and/or data interchange.  

CFPB Evidence of Compliance Development Workgroup Community Page 

Current Goals and Objectives

1)    The "I: Guide has been completed and awaiting submission to CDS and Arch for approval once we have completion of all the core components of an EOC toolkit.

  2)      The development of an EOC toolkit which  complements the "I"Guide. The toolkit currently consists of 4 additional artifacts and a possible new Appendix E. All of Tool Kit's components under development are available on  in the EOC library folder: Works In Progress/EOC Tool KIT

a. Appendix A: Appendix A EOC Shorthand Structure.txt;
b. Appendix B: SRS to Use Case Cross Reference.xlsx,
c. Appendix C: Sample Use Case.docx,
d. Appendix D: EOC Use Case Message.xml; and,
e. Appendix E: SRS3A for XML.xml

3)    Currently working with Appendix D to ensure that the XML message and the Appendix C: Use Case is consistent.  We are looking to have a complete fully formed message that highlights the use of the new EOC related data containers and structures.  

4)    Develop a webinar series on the business benefits in using of EOC in a broader non-servicing context.  

 5)    Continue Work on Industry outreach efforts to promote EOC and MISMO in general  

6)     Explore EOC applicability in other business contexts such as demonstration of compliance with FFIEC CAT tool, counter party management and or exchange of security protocol information.  While not within scope of the original charter, this may well lead to the formation of additional workgroups and has been part of discussions within MISMO since MBA Tech 2016.  

Stake holders

· Issuers
· Lenders
· Investors/GSE
· Servicers
· Rating Agencies
· Trustee
· Law Firms
· Due Diligence Firms
· Accounting Firms
· Regulators CFPP and state

Expected date of completion

Winter Summit 2017 


Bill Klumper, First Mortgage Company,Chief Information Officer  - Co-Chair
Christoper Stookey, Database Analyst, Wells Fargo - Co-Chair

Meet every Tuesday from 1:00PM to 2PM EST. 

Workgroup Meeting Schedule

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