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Licensing Link - June 2025

Licensing Link is a periodic publication that will keep you informed on hot topics and new developments in state licensing laws, and provide practice tips and primers on important issues related to state licensing across the...more

Maryland Update on Licensing Guidance

AT A GLANCE - In response to market concerns regarding licensing guidance for assignees of certain residential mortgage loans and installment loans released by the Maryland Office of Financial Regulation in January, that...more

Maryland Guidance Applies Licensing Requirements to Assignees of Residential Mortgage Loans

On January 10, 2025, the Maryland Office of Financial Regulation (OFR) issued formal guidance asserting that assignees of residential mortgage loans—including certain “passive trusts” that acquire or obtain assignments of...more

NYDFS Finalizes Climate Risk Management Guidance

On December 21, 2023, the New York Department of Financial Services (“NYDFS”) finalized guidance on how the banks and mortgage institutions it regulates (“New York Institutions”) should manage climate-related financial and...more

CFPB Issues New QM Definition and Seasoning Provisions

The Consumer Financial Protection Bureau (“CFPB”) issued two relatively welcome surprises yesterday. First, along with ditching a debt-to-income ratio (“DTI”) ceiling, the agency expanded its proposed general Qualified...more

CFPB Hatches a QM Proposal for GSE Patch

As rumored, the Consumer Financial Protection Bureau (“CFPB”) is proposing to revise its general qualified mortgage definition by adopting a loan pricing test. Specifically, under the proposal, a residential mortgage loan...more

Self-Employed Borrower’s Income – Is the Past Necessarily Prologue?

In a new era of double-digit unemployment resulting from the COVID-19 pandemic, it may be tough for a mortgage lender to predict the amount and stability of someone’s income in order to determine qualification for a home...more

Fannie and Freddie to Relax Servicer Advance Requirements for Loans in Forbearance

This week, the Federal Housing Finance Agency (“FHFA”) announced an eagerly awaited policy allowing Fannie Mae and Freddie Mac (the “Agencies”) to address one aspect of the liquidity crisis for mortgage servicers facing...more

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