Written by: Internal Analysis & Opinion Writers
The Consumer Financial Protection Bureau’s decision to swiftly clear nearly all outstanding “matters requiring attention” (MRAs) is raising alarm among mortgage compliance experts, who warn the move could lead to regulatory gaps and unchecked risks.
MRAs serve as a critical supervisory tool, flagging compliance issues—ranging from minor documentation oversights to serious lending violations—and giving lenders an opportunity to address them before formal enforcement. With a substantial reduction in staff due to layoffs and plans to clear up to 99% of MRAs “by the end of the week,” experts caution that this purge could leave significant issues unresolved.
Mitchel Kider, managing partner at Weiner Brodsky Kider, noted that with workforce reductions exceeding 90%, “there’s not going to be anyone there to follow up on these MRAs.” Even comparatively minor MRAs, which often address matters like quality control, documentation gaps, or procedural slippages, may now slip through the cracks.
David Cotney, a regulatory veteran and senior adviser at FS Vector, emphasized that closing MRAs does not prevent future enforcement—regulators can conduct “lookback” audits to address past deficiencies. However, the current cleanup may unsettle confidence in the bureau’s supervision framework.
Daniella Casseres of Mitchell Sandler views the purge as signaling new enforcement priorities and reduced scrutiny, offering temporary relief to some lenders. Yet she warns: “For others, the impression is that they can take their chances on things they may have received MRAs for in the past.”
Mark McArdle, former assistant director of mortgage markets at the CFPB, acknowledged that although many MRAs are “innocuous,” sweeping closures could inadvertently dismiss substantial compliance concerns. McArdle stressed that while some issues may warrant dismissal, the fast-paced process could result in complications down the line.
With federal oversight waning, attention is shifting to state regulators. As Kider and others point out, the closing of an issue at the federal level doesn’t absolve companies from state-level enforcement. Indeed, mortgage compliance officers may need to adapt to increasingly complex state-by-state interpretations and licensing enforcement.
In response to uncertainty, some lenders are proactively requesting MRA clearances to signal compliance. Others are doubling down on internal audit processes to anticipate scrutiny from future leadership or alternative regulators.
While the CFPB's MRA purge may offer short-term operational reprieve, industry experts agree that maintaining robust, proactive compliance is essential to weathering the uncertainties of an evolving regulatory environment.
