Christina Boyle, vice president and interim head of single-family sales and relationship management at Freddie Mac, commented yesterday that community banks were well-positioned to succeed in the current environment, and "this is a good time for them."

Really? I think Boyle is forgetting one important factor.

Originations are down and compliance costs are through the roof. Mega banks paying out billions of dollars in settlements can easily more afford the added expense of being compliant, but more and more smaller banks are exiting the origination business as a result.

Community banks are, as Boyle said in the same piece, "very trusted as lenders within their own footprint." Agreed. They are incredibly important to our housing industry and should have the support of the government and its agencies.

Instead, community banks have to figure out how to stay on the good side of the CFPB and still make a profit. That isn't going to be easy.

I profiled nine companies for the February issue of HousingWire magazine who were "Compliance All-Stars" offering a wide variety of compliance help, and all of them expressed concern for the smaller players in this environment. The common theme among those varied companies was the need for automation in order to meet the new standards, and their fear that smaller lenders were going to suffer as a result.

Off the record, one of the compliance managers expressed complete disbelief that any lender could meet the new standards without a fully automated system. Obviously, as someone working for a company that creates automated systems, this person sees the world through that lens. But her concerns seem valid when you consider the complexity of the rules, and the uncertainty about how the CFPB will handle enforcement.

What is a "good-faith effort" at writing compliant loans when you're a community bank? What standard will be applied by regulators when approaching these audits?

In our interview for the cover story this month CFPB Director Richard Cordray seemed to be as clear as mud on the issue. "We have attempted to encourage financial institutions that if you are a small lender who has lent responsibly, you pay close attention to your customers and you have had good performance on your loans, even through this terrible financial crisis that we’ve all be through, then you should continue to feel very confident about lending along this model,” Cordray said.

But what does "good performance" mean to the CFPB? And that "current model" wouldn't really be current after Jan. 10.

The compliance companies I interviewed offer a lot of options for smaller lenders, and some even feel a real calling to make sure those smaller lenders can thrive in this environment. But the idea that it's a "good time" for community banks feels like quite a stretch.