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Georgia Legislation Expands Consumer Financial Protections

What Happened? On May 13 and 14, Georgia Governor Brian Kemp signed into law three measures that amend or expand existing consumer financial protections for Georgians, and impact mortgage lending and servicing as follows....more

Maryland Secondary Market Imperiled by Sweeping Regulatory Change Requiring Licensure for All Assignees of Mortgage Loans

What Happened? A development with far-reaching consequences for the secondary market, on January 10, 2025, the Maryland Office of Financial Regulation (“OFR”) issued guidance that requires mortgage trusts and their assignees...more

FHFA Announces UDAP Compliance Expectations

What Happened? On November 29, 2024, the Federal Housing Finance Agency (“FHFA”) released Advisory Bulletin AB 2024-06 (the “Advisory Bulletin”), which sets forth FHFA’s expectations and guidance for Fannie Mae and Freddie...more

VA Issues Guidance on Processing Assumptions with Secondary Financing

What Happened? On August 11, 2024 the Department of Veterans Affairs (the “VA”) released Circular 26-24-17, clarifying how a servicer should process an assumption when there is secondary financing.  Significantly, the VA...more

CFPB Releases Long-Awaited Proposal to Amend Regulation X Loss Mitigation Rules

What Happened? On July 10, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) proposed a rule to amend provisions of its Mortgage Servicing Rules to significantly revamp requirements relating to borrowers...more

FSOC Issues Report on Nonbank Mortgage Servicing Highlighting Strengths, Vulnerabilities and Recommendations

What Happened? In May 2024, the Financial Stability Oversight Council (FSOC or Council) issued a Report on Nonbank Mortgage Servicing (the Report). The Report recognizes the strengths of nonbank mortgage companies (NMCs) and...more

Large Nonbank Ginnie Mae Issuers: Ginnie Mae Wants Your Recovery Plans

What Happened? Following the release of the Financial Stability Oversight Council (FSOC) Report on Nonbank Mortgage Servicing, Ginnie Mae announced in APM 24-08 that certain large nonbank Ginnie Mae Issuers will now be...more

FHA and VA Announce New Loss Mitigation Options

What Happened? Both the FHA and VA have established new loss mitigation options to provide payment reduction to delinquent borrowers.  On February 21, 2024, the Federal Housing Administration (“FHA”) within the U.S....more

Ginnie Mae Imposes Cybersecurity Incident Notification Obligation

What Happened? On March 4, 2024, Ginnie Mae issued All Participant Memorandum (APM) 24-02 to impose a new cybersecurity incident notification requirement. Ginnie Mae has also amended its Mortgage-Backed Securities Guide to...more

New York DFS to Impose Climate Change Safety and Soundness Expectations on Mortgage Lenders, Servicers, and other Regulated...

What Happened? On December 21, 2023, the New York Department of Financial Services (“NYDFS”) published an 18-page guidance document (the “Guidance”) on managing material, financial and operational risks due to climate...more

Consumer Finance ABstract 2023 Year-End Reprise

As we reflect on the previous year and look toward the new year, we thought you’d appreciate our top 20 most-read Consumer Finance ABstract posts from 2023...more

CFPB’s Message to Mortgage Servicers: Make Sure You Comply with RESPA’s Force-Placed Insurance Requirements

A&B Abstract: In Case You Missed It:  At the recent Federal Housing Finance Agency’s Symposium on Property Insurance, CFPB Director Rohit Chopra spoke about force-placed insurance and conveyed the following message: “The...more

FSOC Approves Analytic Framework for Financial Stability Risks and Guidance on Nonbank Financial Company Designations

A&B Abstract: On November 3, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) unanimously approved final versions of: (1) the new Analytic Framework for Financial Stability Risk...more

FSOC Issues Proposed Update to Interpretative Guidance on Nonbank Financial Company Designations

A&B Abstract: On April 21, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) issued for public comment (1) a proposed analytic framework setting forth FSOC’s approach to identifying,...more

The COVID-19 National Emergency is Ending: Are mortgage servicers ready?

A&B Abstract: On January 30, 2023, President Biden informed Congress that the COVID-19 National Emergency (the “COVID Emergency”) will be extended beyond March 1, 2023, but that he anticipates terminating the national...more

New York Foreclosure Abuse Prevention Act Curtails Servicers’ Options

A&B ABstract: Effective on approval by Governor Kathy Hochul on December 30, 2022, New York Assembly Bill 7737b – the Foreclosure Abuse Prevention Act (the “Act”) became law....more

Moving to Address Appraisal Bias, Agencies and the Appraisal Foundation Issue Updates

A&B ABstract:  A year and a half after President Biden’s announcement of the Interagency Task Force on Property Appraisal and Valuation Equity (“PAVE”), the past weeks have seen a flurry of activity from federal agencies and...more

CFPB Proposes Nonbank Registry to Focus on Compliance “Recidivism”

A&B ABstract: On December 12, 2022, the Consumer Financial Protection Bureau (CFPB) announced a proposed rule to require certain non-banks to register with the agency when they become subject to a public written order or...more

Assumptions on the Rise: Are You Ready for Mortgage Assumptions?

A&B ABstract: Mortgage assumptions – where a buyer assumes the existing mortgage loan of a seller – have fluctuated in popularity since the 1980s....more

GSEs to Require Mortgage Servicers to Obtain and Maintain Fair Lending Data

A&B Abstract: On August 10, 2022, the Federal Housing Finance Agency (“FHFA”) announced that Fannie Mae and Freddie Mac (the “GSEs”) will require mortgage servicers to obtain and maintain fair lending data on their loans,...more

Georgia Amends its Residential Mortgage and Installment Loan Laws

A&B Abstract: On May 2, 2022, Georgia Governor Brian Kemp signed HB 891 and SB 470 into law.  HB 891, effective July 1, 2022, updates various laws enforced by the Georgia Department of Banking and Finance (the “Department”)...more

Connecticut and Maryland Adopt Model Mortgage Servicer Prudential Standards

A&B Abstract: On May 24, 2022, Connecticut enacted legislation that, among other things, adds financial condition and corporate governance requirements for certain licensed mortgage servicers (the “CT Standards”). In similar...more

One Person’s Junk Fee Is Another’s Treasure

The Consumer Financial Protection Bureau has sought comments on how it can best crack down on what it calls “junk fees.” Our Financial Services & Products Group examines how mortgage servicing is singled out and why mortgage...more

[Webinar] Fair Lending Webinar Series Part Two – Fair Valuations - January 25th, 2:00 pm - 3:00 pm ET

Please join Alston & Bird's consumer finance attorneys and an economist from Charles River Associates as they discuss new legal and practical approaches to fair lending, fair valuations, and fair servicing. This program will...more

Biden-Harris Administration Announces Extension of COVID-19 Foreclosure Moratorium

A&B Abstract: Today, the Biden Administration announced an extension of the foreclosure moratorium for federally-backed mortgage loans (the “Presidential Announcement”). ...more

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