The CFPB recently announced the publication of the Home Mortgage Disclosure Act (HMDA) Modified Loan Application Data for 2023. The data is available on the Federal Financial Institutions Examination Council (FFIEC) website....more
As previously reported, in November 2022 the Department of Veterans Affairs (VA) issued a proposal to update its rules for interest rate reduction refinancing loans (often referred to as “IRRRLs”) to conform with VA loan...more
3/11/2024
/ Comment Period ,
Consumer Financial Products ,
Department of Veterans Affairs ,
Fees ,
Financial Services Industry ,
Interest Rate Reduction Refinancing Loan (IRRRL) ,
Loans ,
Mortgages ,
Proposed Rules ,
Refinancing ,
VA Loans ,
Veterans
The U.S. Department of Veterans Affairs (VA) recently issued Circular 26-23-10, Change 1, Circular 26-24-5 and an Exhibit to address fees that may be imposed in connection with the assumption of a VA-guaranteed home loan....more
The U.S. Department of Housing and Urban Development (HUD) recently announced a Payment Supplement loss mitigation program for Federal Housing Administration (FHA) insured Title 2 mortgage loans, the details of which are set...more
As previously reported, in 2023 bills were introduced in the U.S. House of Representatives (H.R. 4198) and the U.S. Senate (S. 3502) to amend the Fair Credit Reporting Act (FCRA) to curtail the practice of trigger leads with...more
The U.S. Department of Housing and Urban Development (HUD) recently issued a press release announcing a 2023 update to its Equity Action Plan. The Equity Action Plan is part of HUD’s efforts to implement President Biden’s...more
2/19/2024
/ Consumer Financial Products ,
Fair Housing Act (FHA) ,
Fannie Mae ,
FHFA ,
Financial Services Industry ,
Freddie Mac ,
HUD ,
Loans ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Racial Bias
The Federal Financial Institutions Examination Council (FFIEC) recently issued a statement of principles related to valuation discrimination and bias for member entities to consider in their consumer compliance and safety and...more
The Department of Justice (DOJ) announced that Patriot Bank (Patriot or Bank) has agreed to pay $1.9 million to resolve allegations that the Bank engaged in a pattern or practice of redlining majority-Black and Hispanic...more
1/31/2024
/ Banks ,
Consent Order ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
ECOA ,
Fair Housing Act (FHA) ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgages ,
Race Discrimination ,
Redlining
The Federal Housing Finance Agency (FHFA) recently published another FHFA Insights blog post addressing the underutilization of appraisal time adjustments by appraisers that is a companion to an FHFA Insights blog post that...more
The Federal Housing Finance Agency (FHFA) recently published a FHFA Insights blog post that cites the underutilization of appraisal time adjustments by appraisers....more
The CFPB recently announced that the platform for the submission of Home Mortgage Disclosure Act (HMDA) data collected in 2023 is now available for the submission of the data. The platform may be accessed here. HMDA data for...more
1/5/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Data Collection ,
Data Management ,
Financial Services Industry ,
HMDA ,
Loan Applications ,
Loans ,
Mortgages ,
Online Platforms
The CFPB and Justice Department filed a joint complaint last week in a Texas federal district court against Colony Ridge Development, LLC and three related entities (collectively, “Colony Ridge”) in which the agencies allege...more
12/28/2023
/ Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Department of Justice (DOJ) ,
ECOA ,
Enforcement Actions ,
Financial Services Industry ,
ILSA ,
Mortgage Lenders ,
Mortgages ,
Predatory Lending ,
Statutory Violations
The CFPB recently released results of a study of residential mortgage refinance loans from the first quarter of 2013 to the first quarter of 2023, focusing on differences between cash-out and non-cash-out (or rate and term)...more
Bills have been introduced in the U.S. House of Representatives (H.R. 4198) and the U.S. Senate (S. 3502) to amend the Fair Credit Reporting Act (FCRA) to curtail the practice of trigger leads with mortgage loans....more
12/20/2023
/ Consumer Financial Products ,
Consumer Reporting Agencies ,
Credit Reports ,
Credit Unions ,
Depository Institutions ,
Fair Credit Reporting Act (FCRA) ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Proposed Legislation ,
Real Estate Transactions ,
Regulatory Agenda
On December 8, 2023, oral arguments were held before a three judge panel of the U.S. Court of Appeals for the Seventh Circuit in the CFPB v. Townstone Financial case, in which the CFPB alleges that Townstone Financial, a...more
12/14/2023
/ Chevron Deference ,
Consumer Credit Protection Act (CCPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Discriminatory Lending Practices ,
ECOA ,
Fair Housing Act (FHA) ,
Financial Services Industry ,
Mortgages ,
Oral Argument ,
Redlining ,
Regulation B ,
SCOTUS
The U.S. Department of Veterans Affairs (VA) recently issued Circular 26-23-25 in which VA “is strongly encouraging a foreclosure moratorium on all VA-guaranteed loans through May 31, 2024.” Additionally, VA “urges servicers...more
The Federal Housing Administration (FHA) recently proposed enhancements to its 203(k) rehabilitation mortgage loan program. The proposed enhancements are set forth in a draft Mortgagee Letter. FHA will accept feedback on the...more
The U.S. Department of Housing and Urban Development (HUD) recently announced the 2024 loan limits for FHA insured forward mortgage loans and FHA insured Home Equity Conversion Mortgages (HECMs). The announcements were made...more
11/30/2023
/ Consumer Financial Products ,
Fair Housing Act (FHA) ,
Fannie Mae ,
Financial Services Industry ,
Freddie Mac ,
HECM ,
HUD ,
Loans ,
Mortgage Lenders ,
Mortgagee Letters ,
Mortgages
The Federal Housing Finance Agency (FHFA) recently announced the conforming loan limits for residential mortgage loans acquired by Fannie Mae and Freddie Mac in 2024. Fannie Mae addresses the limits in Lender Letter 2023-09....more
The CFPB recently approved an application (Application) from the Independent Community Bankers Association (ICBA) for alternative disclosures under the Truth in Lending Act (TILA)/Real Estate Settlement Procedures Act (RESPA)...more
11/29/2023
/ Construction Industry ,
Construction Loans ,
Construction Project ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Financial Institutions ,
Financial Services Industry ,
Independent Community Bankers of America (ICBA) ,
Mortgages ,
Real Estate Development ,
RESPA ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Truth in Lending Act (TILA)
The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more
11/15/2023
/ Consumer Financial Protection Bureau (CFPB) ,
Credit ,
Exemptions ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Financial Transactions ,
Inflation Adjustments ,
Loans ,
Mortgages ,
OCC ,
Proposed Rules ,
Regulation M ,
Regulation Z ,
Threshold Requirements ,
Truth in Lending Act (TILA)
Recently the U.S. Department of Justice (DOJ) entered into a proposed consent order with Ameris Bank to resolve allegations of redlining from 2016 through 2021 in majority Black and Hispanic areas in the Bank’s Jacksonville,...more
10/30/2023
/ Banks ,
Community Reinvestment Act ,
Consent Order ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
ECOA ,
Enforcement Actions ,
Fair Housing Act (FHA) ,
Fair Lending ,
Financial Services Industry ,
Mortgages ,
Race Discrimination ,
Redlining ,
Regulation B
The Department of Justice (DOJ) announced a settlement agreement with Washington Trust Company, of Westerly (WTC) to resolve claims that WTC redlined majority Black and Hispanic neighborhoods in Rhode Island....more
10/24/2023
/ Consent Order ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
ECOA ,
Enforcement Actions ,
Fair Housing Act (FHA) ,
Financial Services Industry ,
Mortgage Loan Officer ,
Mortgages ,
Race Discrimination ,
Redlining ,
Regulation B ,
Rhode Island ,
Settlement
The CFPB recently released a report entitled Data Point: 2022 Mortgage Market Activity and Trends based on 2022 data reported by lenders under the Home Mortgage Disclosure Act (HMDA)....more
The CFPB recently posted on its website a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified...more
9/19/2023
/ CARD Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Price Index ,
Credit Cards ,
Dodd-Frank ,
Final Rules ,
Financial Services Industry ,
HOEPA ,
Late Fees ,
Mortgages ,
Proposed Rules ,
Regulation Z