A&B ABstract - In keeping with broader scrutiny on non-bank servicers, the Federal Housing Finance Agency (FHFA) is proposing new financial eligibility requirement for non-bank servicers doing business with Fannie Mae or...more
A&B Abstract:
On January 27, 2020, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) published a policy statement announcing a new designation for CFPB guidance, known as “Compliance Aids,” and explaining the...more
New York’s amended mortgage loan servicer regulations are a substantial departure from previous versions and could go beyond federal rules. Our Financial Services & Products Group delves into technicalities and ramifications...more
A&B ABstract: Effective March 5, 2020, New York Assembly Bill 5626 (“AB 5626”) regulates the origination and servicing of the federal U.S. Department of Housing and Urban Development (“HUD”) home equity conversion mortgages...more
The New York Department of Financial Services (“NYDFS”) has issued final mortgage servicer business conduct rules found in Part 419 of the Superintendent’s Regulations....more
A&B Abstract:
On November 20, 2019, the Consumer Financial Protection Bureau (the “Bureau” or “CFPB”) published its Fall 2019 Rulemaking Agenda (the “Rulemaking Agenda”) as part of the Fall 2019 Unified Agenda of Federal...more
A&B Abstract:
Maryland’s inspection fee statute has been interpreted by the Maryland Court of Appeals and the Maryland Office of the Commissioner of Financial Regulation (“OCFR”) to apply both at the time of origination...more
A&B ABstract: Servicers should be aware of changes being made to the Department of Defense’s (“DoD”) Servicemembers Civil Relief Act (“SCRA”) website in response to a complaint that the DoD failed to protect the privacy of...more
A&B Abstract: In an effort to incent large depository institutions to return to FHA lending, the U.S. Department of Housing and Urban Development (“HUD”) and the U.S. Department of Justice (“DOJ”) entered into a Memorandum...more
A&B ABstract: Amid growing concerns of a student loan crisis, proposed Massachusetts H. 3977 is worth watching....more
A&B ABstract: On October 18, 2019, the Supreme Court granted certiorari in Seila Law v. CFPB to decide the constitutionality of the Consumer Financial Protection Bureau’s leadership structure....more
A&B ABstract: The South Carolina Department of Consumer Affairs (“Department”) announced that it is soliciting comments on proposed Regulation 28-75, which would provide mortgage lenders with additional guidance on the...more
A&B Abstract: In a series of 2019 settlement agreements, the Massachusetts Attorney General has publicly provided insights into her compliance expectations for residential mortgage servicers. ...more
A&B ABstract -
The Conference of State Bank Supervisors (CSBS) revolutionized state licensing with the National Mortgage Licensing System (NMLS) by providing a more uniform approach to state licensing of non-bank financial...more
A&B Abstract This blog post is part five of a five-part series examining the Consumer Financial Protection Bureau’s (the “CFPB” or “Bureau”) proposed rule amending Regulation F (the “Proposed Rule”), which implements the Fair...more
It’s hot out there and the market’s even hotter! Cool off with the latest issue of the Structured Finance Spectrum, our newsletter featuring what’s new and newsworthy in structured finance.
...more
A&B Abstract:
Effective October 1, 2019, the Maryland Commissioner of Financial Regulation will impose new net worth requirements on licensees. ...more
A&B Abstract: Effective October 1, 2019 only Connecticut licensed attorneys can conduct real estate closings in the state for certain mortgage loan transactions....more
A&B Abstract: If enacted, the recently introduced Appraisal Reform Act of 2019 would amend RESPA to require the disclosure of the appraisal management fee separate from the appraisal fee on the loan estimate (LE) and closing...more
On June 25, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) kicked off its symposia series with a panel discussion of whether the Bureau should use its rulemaking authority to further define “abusive acts or...more
Original creditors, third-party debt collection agencies, and buyers of delinquent consumer debt who hire third parties to collect consumer debt on their behalf, take note. According to the Supreme Judicial Court, the...more
SECURITIZATION SIDE NOTES – EU Risk Retention: Did This Come with a Gift Receipt? We’d Like to Return It -
A new year brings new laws and regulations into effect, in this case a complicated and confusing gift from our...more
REGULATORY REPORT – FASB’s New Current Expected Credit Loss Model -
Sharpen your pencils and put on your green eyeshades – the Financial Accounting Standards Board is making major changes to the credit loss accounting...more
On May 24, 2018, the President signed the Economic Growth, Regulatory Relief, and Consumer Protection Act into law. A product of rare bipartisanship, the Regulatory Relief Act makes modest reforms to the Dodd–Frank Wall...more
Maryland, suspicious of what it sees as moves to dismantle protections of student loan borrowers, is creating new hoops for passive, secondary market investors to jump through. Our Financial Services & Products Group reviews...more