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Kohrman Jackson & Krantz LLP

Navigating Loan Default: Practical Strategies for Borrowers

Commercial mortgage delinquency rates are on the uptick. The United States economy is shrinking according to Commerce Department measurements. Economic volatility is the new norm. As borrowers navigate economic ebbs and...more

A&O Shearman

PRA to review Loan to Income flow limit rule and offers interim modification by consent

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The Prudential Regulation Authority (PRA) has announced it will be reviewing the Loan to Income (LTI) flow limit requirements, following the Financial Policy Committee's (FPC) recommendation, as stated in its July financial...more

Miles & Stockbridge P.C.

Fannie Mae Updates Multifamily Loan Documents

Fannie Mae recently announced updates to its Multifamily Loan Documents with Lender Letter (25-04). Since that time, Fannie Mae released a revised Lender Letter (25-04R) that changed the mandatory date for use of the loan...more

Mayer Brown

Georgia On (Regulators’) Mind: Significant Changes Coming to Georgia Residential Mortgage Act

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On May 14, 2025, Governor Brian Kemp signed Georgia House Bill 15 into law. House Bill 15, which will take effect on July 1, 2025, will implement several major changes to Georgia’s residential mortgage licensing law, the...more

Herbert Smith Freehills Kramer

Insurers in the securitisation market: Securitisations of lifetime mortgages

We have seen a marked increase in the volume of structured finance transactions involving lifetime mortgage products in recent years (both funding transactions and the sale and purchase of lifetime mortgage books through...more

Sheppard Mullin Richter & Hampton LLP

Maryland Enacts Law Exempting Passive Trusts from Mortgage and Installment Loan Licensing Requirements

In January 2025, the Maryland Office of Financial Regulation (the “OFR”) issued a guidance stating that assignees of residential mortgage loans, including certain passive trusts, were required to hold a Maryland mortgage...more

GeoDataVision

Potential Improvements for CRA (Part 4b of 4)

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In the first 3 articles in this series (1, 2, 3), we identified fatal flaws in the 2023 CRA rule. In Parts 4a – 4c we propose the regulators consider potential improvements to the rule when they publish the Notice of Proposed...more

Alston & Bird

Governor Moore Signs Legislation Exempting “Passive Trusts” from Licensure in Maryland

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In a highly anticipated and welcome development, on April 22, 2025, Maryland Governor Wes Moore signed into law the Maryland Secondary Market Stability Act of 2025 (emergency measures HB 1516 and its companion SB 1026) with...more

Orrick, Herrington & Sutcliffe LLP

North Dakota expands its financial data security framework, includes alternative financing providers to obtain money broker...

On April 11, North Dakota enacted HB 1127 (the “Act”), amending the regulatory framework for financial institutions within the state by establishing a new chapter focused on data security programs. The Act amends various...more

Orrick, Herrington & Sutcliffe LLP

CFPB publishes 2024 HMDA Modified Loan Application Register data

On March 31, the CFPB announced it published the 2024 HMDA Modified Loan Application Register data on the FFIEC’s HMDA Platform. The data, sourced from nearly 5,000 HMDA filers, included loan-level information to assess...more

GeoDataVision

Former Senator: Bankers Can’t Be Passive About Proposed CRA Rule Rollback

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Yesterday, as I was writing this article the news broke about the regulators deciding they intend to rescind the 2023 CRA rule. My first reaction was to toss this article in the “trash” folder. But upon further reflection I...more

Orrick, Herrington & Sutcliffe LLP

OCC reports improved mortgage performance in Q4 2024

On March 24, the OCC published its Mortgage Metrics Report for the fourth quarter of 2024. The Report analyzed the performance of first-lien residential mortgage loans serviced by seven national banks in the U.S. As of...more

Sheppard Mullin Richter & Hampton LLP

Maryland OFR Responds to Market Concerns Over Licensing Requirements for Mortgage and Installment Loan Assignees

On February 18, the Maryland Office of Financial Regulation (OFR) issued an alert to address industry concerns regarding its January guidance on licensing requirements for assignees of residential mortgage and installment...more

Miles & Stockbridge P.C.

What You Need to Know About Freddie Mac’s Recent Update

Freddie Mac published last Thursday an update to the Freddie Mac Guide, which included a discussion of various underwriting, fraud detection and loan document changes. Here's what you need to know...more

Mayer Brown

Maryland Update on Licensing Guidance

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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

A&O Shearman

Good faith in secured finance?

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The court implied a good faith term constraining a lender’s discretion to refuse a borrower's request to dispose of assets in a secured financing context. A power to consider requests for disposals - A facility agreement...more

Crunched Credit

Even If We Don’t Want To, We Should Still Talk About REMIC More 

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As regular readers of CrunchedCredit will know, I recently pitched the idea of amending our hoary old REMIC statute to allow additions of collateral after the startup date window to allow modification to performing loans (and...more

Orrick, Herrington & Sutcliffe LLP

California and federal financial regulatory agencies issue statement on California wildfires to guide financial institutions

On January 14, the DFPI, in collaboration with the FDIC, the Fed, the NCUA and the OCC (collectively, the “agencies”) issued a joint statement addressing the impact of the California wildfires and straight-line winds on...more

Orrick, Herrington & Sutcliffe LLP

Maryland Mortgage Loan Purchasers Face New License Requirement

Financial institutions that purchase mortgage loans in Maryland, including securitization trusts and other secondary market purchasers, face a new requirement to obtain a state license. The Maryland Office of Financial...more

Blank Rome LLP

AB 238 Mortgage Deferment Act for California Wildfire: Mortgage Forbearance Relief

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AB 238, also referred to as the Mortgage Deferment Act, to add Title 19.1 § 3273.20 et seq. (the “Mortgage Deferment Act” or the “Act”), was introduced in the California legislature on January 13, 2025 to provide essential...more

Cadwalader, Wickersham & Taft LLP

Maryland Emergency Regulations

On January 10, 2025, the Maryland Office of Financial Regulation issued emergency regulations revised to clarify that “passive trusts” holding residential mortgage loans must obtain a Mortgage Lender License and if the trusts...more

Ballard Spahr LLP

Led by California MBA, five banks provide mortgage relief for fire victims

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Led by the California Mortgage Bankers Association, five lenders have made commitments to provide mortgage relief for the victims of the California wildfires....more

Allen Matkins

What will be the big trends in commercial real estate in 2025 related to financing and capital markets?

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Real estate lending will continue to be impacted by elevated interest rates, limited borrowing capacities, and slow transaction volumes. Floating-rate debt will likely be the chosen option by borrowers. Additionally,...more

Ballard Spahr LLP

CFPB issues final rule amending Regulation Z CARD Act, HOEPA and QM dollar amounts

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The CFPB has issued a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z under the Truth in Lending Act (TILA) that implement the CARD Act, Home Ownership and Equity...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M

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The CFPB, Fed, and OCC have announced that they are increasing exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2025 through December 31, 2025, these exemption thresholds are...more

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